https://www.taxtmi.com/caselaws?id=784610 The dominant issue was whether the PCIT validly assumed revisionary jurisdiction under s 263 by treating the assessment as erroneous and prejudicial to the Revenue. Corporate club membership fees incurred for business purposes were allowable under s 37(1) per binding SC/HC precedent; hence the AO's allowance was not erroneous, and revision failed on this issue. ESOP expenditure, incurred as employee compensation in accordance with regulatory/accounting norms, was a permissible business deduction; therefore revision was unsustainable. CSR amounts, once disallowed under s 37(1), could still qualify for s 80G if statutory conditions were met; the AO's plausible view barred revision. Stock exchange "penalties" were compensatory charges for procedural lapses, not hit by Expln 1 to s 37(1); revision was unjustified. Interest under s 36(1)(iii) lacked nexus with CWIP and Ind AS 116 effects were reversed; the proviso did not apply, so revision was invalid. The appeal was allowed. en-us Tue, 06 Jan 2026 00:00:00 +0530 Thu, 08 Jan 2026 08:22:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784610 The dominant issue was whether the PCIT validly assumed revisionary jurisdiction under s 263 by treating the assessment as erroneous and prejudicial to the Revenue. Corporate club membership fees incurred for business purposes were allowable under s 37(1) per binding SC/HC precedent; hence the AO's allowance was not erroneous, and revision failed on this issue. ESOP expenditure, incurred as employee compensation in accordance with regulatory/accounting norms, was a permissible business deduction; therefore revision was unsustainable. CSR amounts, once disallowed under s 37(1), could still qualify for s 80G if statutory conditions were met; the AO's plausible view barred revision. Stock exchange "penalties" were compensatory charges for procedural lapses, not hit by Expln 1 to s 37(1); revision was unjustified. Interest under s 36(1)(iii) lacked nexus with CWIP and Ind AS 116 effects were reversed; the proviso did not apply, so revision was invalid. The appeal was allowed. Case-Laws Income Tax Tue, 06 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784610