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    <title>2025 (12) TMI 146 - ITAT, MUMBAI</title>
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    <description>Revision under section 263 was held unsustainable where the Assessing Officer had adopted a plausible view on the assessee&#039;s CSR-related claim for deduction under section 80G. The issue was treated as highly debatable, with coordinate bench decisions recognising that CSR expenditure could qualify under section 80G. In that setting, the original assessment under section 143(3) was not regarded as erroneous or prejudicial merely because a different view was possible. The revisionary action was therefore characterised as a change of opinion and could not be maintained, and the assessment order was restored.</description>
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      <description>Revision under section 263 was held unsustainable where the Assessing Officer had adopted a plausible view on the assessee&#039;s CSR-related claim for deduction under section 80G. The issue was treated as highly debatable, with coordinate bench decisions recognising that CSR expenditure could qualify under section 80G. In that setting, the original assessment under section 143(3) was not regarded as erroneous or prejudicial merely because a different view was possible. The revisionary action was therefore characterised as a change of opinion and could not be maintained, and the assessment order was restored.</description>
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