2025 (8) TMI 521

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....e Appellant : Shri R. Sivaraman, Advocate For The Respondent : Shri Nilay Baran Som, CIT ORDER PER JAGADISH, A.M : Aforesaid appeal filed by the assessee for Assessment Year (AY) 2018-19 arises out of the order of Learned Principal Commissioner of Income Tax-3, Chennai [hereinafter "PCIT"] dated 31.03.2024. 2. The effective ground of appeal in this appeal of assessee is against the ....

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.... payment to trusts as part of CSR expenses and A.O has allowed the deduction. The Ld PCIT held that there is failure on the basis of assessing officer to cause necessary enquiries and also to apply law properly in respect of the said claim, therefore the order passed by the AO is erroneous and prejudicial to the interest of revenue and directed A.O to disallow the claim of deduction u/s. 80G of th....

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.... to revise u/s. 263 of the Act. The Ld. AR submitted that the Ld. PCIT, while referring to Explanation-2 to section 263 of the Act has not pointed as to what enquiry or verification, A.O has not conducted. The Ld. AR on holding the non application of law properly by the A.O submitted that the Honorable ITAT has consistently held, deduction u/s. 80G on such donations are to be allowed and submitted....

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....tion and allowed the claim after verification. The Ld. PCIT has not made out a case as to what enquiry was not conducted by the AO in order to invoke Explanation 2 to section 263 of the Act. As regard to Ld. PCIT finding that A.O has not applied the law properly on the claim of deduction under 80G, we find that ITAT, Banglore Bench in the case of M/s Goldman Sachs Services Pvt Ltd in IT(TP)A No.23....