PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER:

This appeal has been filed by the Assessee against the order passed by the Ld. Principal Commissioner of Income Tax-3, (in short “Ld. PCIT”), Ahmedabad vide order dated 30.03.2025 passed for A.Y. 2020-21.

2. The assessee has taken the following grounds of appeal:

“Order passed u/s 263 of the Act is bad in law and without jurisdiction:

1. erred in passing the order u/s 263 of Act without providing an Opportunity of being heard on the issue for which assessment is set aside;

2. erred in setting aside the assessment completed u/s 143(3) r.w.s. 144B of the Act by the Faceless assessing officer as erroneous and prejudicial to the interest of revenue without appreciating that such an action can be taken only by PCIT having jurisdiction under Faceless regime;

3. erred in setting aside the assessment completed u/s. 143(3) rrw.s 144B of the Act for a debatable issue of allowability of deduction under section 80G on donations made as a part of CSR e