2025 (11) TMI 217

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.... to the assessment year (A.Y.) 2020-21. 2. The grounds raised by the assessee are as under: Validity of revision proceedings under section 263 of the Act 1. On facts and circumstances of the case and in law, the leamed PCIT erred in passing an order under section 263 of the Act without appreciating that the assessment order dated 5 September 2022 passed by the learned Assessing Officer ('AO') under section 143(3) read with section 144B of the Act was neither erroneous nor prejudicial to the interest of the revenue and thus, the order under section 263 of the Act is without jurisdiction and bad-in-law. Deduction under section 80G of the Act 2 On facts and circumstances of the case and in law, th....

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....he Act. According to ld. PCIT, CSR expenses not being admissible as expenditure u/s. 37(1) of the Act, the A.O. should not have allowed the claim of deduction u/s. 80G of the Act out of such expenses. He further noticed that as per audit report, sundry balance amounting to Rs. 84,742/- though has been written back, but it is required to be added to the income u/s. 41(1) of the Act, which has not been done. He observed, while completing the assessment, the A.O. having not verified these issues, the assessment order is erroneous and prejudicial to the interest of the Revenue. Accordingly, he issued a show cause notice to the assessee to explain why the assessment order should not be revised. In response to the said show cause notice, the asse....