JMS Mining (P.) Ltd. v. PCIT (2021) 190 ITR 702 / 91 ITR 80 (Kol.)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-GSR expenses-Donation made to two trusts registered u/s 80G(5)(vi) of the Act-Revision was held to be not valid. [S. 37(1), 80G(5)(vi)]

Held that since donation on account of CSR was made by assessee to charitable trusts which were duly registered under section 80G(5)(vi), assessee was entitled to claim deduction under section 80G in respect of such contribution. Since action of Assessing Officer in allowing claim under section 80G was a plausible view, impugned invocation of revision jurisdiction under section 236 was unjustified. (AY. 2016-17)