2025 (9) TMI 581

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....e Income-Tax Act, 1961 [hereinafter referred to as "the Act" for short] for Assessment Year (AY) 2020- 2021. 2. The sole issue involved in this appeal is as to whether the Ld.PCIT was justified in exercising his revision jurisdiction u/s. 263 of the Act, on an issue where there are divergent views of the Tribunal, one in favour of assessee and the other in favour the Revenue. 3. The PCIT observed from the assessment records that the AO had allowed a deduction of Rs. 3,36,70,305/- (being 50% of total donation paid by the assessee of Rs. 6,73,40,611/-) u/s. 80G of the Income Tax Act, 1961. The PCIT observed that a big portion of Corporate Social Responsibility (CSR) expenditure has been claimed as deduction u/s. 80G of the Act, which ot....

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....rovisions of Section 80G allow deductions for donations made to approved institutions, unless explicitly excluded by the Act. That since the donations were made to institutions eligible under Section 80G, and there was no specific legislative restriction barring CSR-related donations from this deduction, hence the same were eligible for deduction, except for contributions to the Swachh Bharat Kosh and Clean Ganga Fund, which were explicitly excluded. Identical view in favour of the assessee on this issue has been taken by the Co-ordinate Ahmedabad Bench of the Tribunal in the case of "Gujarat State Financial Services Ltd. vs. DCIT" [174 Taxmann.com 461 (Ahmedabad-Trib.)] and the Delhi Bench in the case of "Interglobe Technology Quotient (P.....