Section 263 revision without recording errors found in order is unsustainable

Diamond Beverages Private Limited Vs Pr. CIT (ITAT Kolkata) Held that Commissioner should not simply relegate the point that the assessment order is erroneous to the AO. The Commissioner, after analyzing the record, ought to have recorded a categorical finding and provided valid reasons as to how the assessment order is erroneous. Revision unsustainable Facts- The assessee had incurred a sum of Rs.7,50,000/- as Corporate Social Responsibility (CSR) Expenditure. According to assessee, it suo moto disallowed the CSR expenditure but claimed it u/s. 80G of the Act because the trust and institution...