https://www.taxtmi.com/caselaws?id=783497 ITAT Ahmedabad allowed the assessee's appeal and quashed the Pr. CIT's revisionary order passed u/s 263. It held that the AO had already examined the alleged excess depreciation on residential building, plant and machinery, as well as disallowance u/s 14A r.w.s. 8D, and these issues were identical to those considered in a prior year, rendering the Pr. CIT's interference a mere change of opinion. Regarding deduction u/s 80G on CSR expenditure, ITAT accepted that the AO had raised queries and the assessee had duly replied, so the Pr. CIT could not invoke s.263 to substitute his subjective second opinion. en-us Fri, 12 Dec 2025 00:00:00 +0530 Wed, 17 Dec 2025 08:28:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783497 ITAT Ahmedabad allowed the assessee's appeal and quashed the Pr. CIT's revisionary order passed u/s 263. It held that the AO had already examined the alleged excess depreciation on residential building, plant and machinery, as well as disallowance u/s 14A r.w.s. 8D, and these issues were identical to those considered in a prior year, rendering the Pr. CIT's interference a mere change of opinion. Regarding deduction u/s 80G on CSR expenditure, ITAT accepted that the AO had raised queries and the assessee had duly replied, so the Pr. CIT could not invoke s.263 to substitute his subjective second opinion. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783497