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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
PAWAN SINGH, J
The Ruby Mills Limited – Appellant
Versus
Pr. Commissioner of Income Tax (Central)-5 – Respondent
| Table of Content |
|---|
| 1. grounds of appeal and factual background. (Para 1 , 2) |
| 2. court's observations and reasoning on csr deductions. (Para 3) |
| 3. arguments regarding the legality of the pcit's order. (Para 4 , 5) |
| 4. ratio decidendi on jurisdictional issues under section 263. (Para 6 , 7) |
| 5. final conclusion allowing the appeal. (Para 8) |
PER PAWAN SINGH, JUDICIAL MEMBER:
1. This appeal by assessee is directed against the order of Principal Commissioner of Income Tax (PCIT) – 8, Mumbai dated 10.03.2025 for AY 2020-21. The assessee has following grounds of appeal:
1. On the facts and in the circumstances of the appellant's case and in law, the Ld. Principal Commissioner of Income Tax, erred on facts and in law in passing order u/s 263 directing the Assessing Officer to re-examine assessment order dated 29.09.2022 u/s 143(3) of the Income Tax Act, 1961 which is illegal, bad-in-law and void for want of jurisdiction.
2. On the facts and in the circumstances of the appellant's case and in law, the Ld. Principal Commissioner of Income Tax, erred in passing the revisionary order u/s 263 of the Income Tax Act, 1961 despite the fact that the twin perquisites of initiating revisionary action i.e., the or
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