https://www.taxtmi.com/caselaws?id=465603 Revision under s.263 was invoked on the ground that the AO's order allowing 50% deduction u/s 80G for Corporate Social Responsibility expenditure (otherwise disallowed under Explanation 2 to s.37(1)) was erroneous and prejudicial to revenue. The ITAT held that eligibility of CSR expenditure for deduction u/s 80G is a debatable issue on which Tribunals have taken a consistent view permitting such claim; hence the AO's view in the original assessment was a plausible view. The Pr. CIT's revision merely substituted another plausible view, amounting to impermissible change of opinion. The s.263 order was set aside and the AO's assessment restored; appeal allowed. en-us Fri, 20 Jun 2025 00:00:00 +0530 Fri, 02 Jan 2026 07:07:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465603 Revision under s.263 was invoked on the ground that the AO's order allowing 50% deduction u/s 80G for Corporate Social Responsibility expenditure (otherwise disallowed under Explanation 2 to s.37(1)) was erroneous and prejudicial to revenue. The ITAT held that eligibility of CSR expenditure for deduction u/s 80G is a debatable issue on which Tribunals have taken a consistent view permitting such claim; hence the AO's view in the original assessment was a plausible view. The Pr. CIT's revision merely substituted another plausible view, amounting to impermissible change of opinion. The s.263 order was set aside and the AO's assessment restored; appeal allowed. Case-Laws Income Tax Fri, 20 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465603