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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Sandeep Singh Karhail, J, Om Prakash Kant, ACJ
Abhay Ispat (India) Pvt. Ltd. – Appellant
Versus
Principal Commissioner of Income Tax - 6 – Respondent
| Table of Content |
|---|
| 1. timeliness and appropriateness of invoking revisionary powers comparing legal standing. (Para 1 , 2 , 3) |
| 2. csr deduction arguments based on statutory compliance and its impact on assessments. (Para 4 , 5 , 6) |
| 3. assessing the nature of csr contributions and their eligibility for deductions. (Para 11 , 13) |
ORDER
PER SANDEEP SINGH KARHAIL, J.M.
The assessee has filed the present appeal against the impugned order dated 22/03/2025, passed under section 263 of the Income Tax Act, 1961 (“the Act”) by the learned Principal Commissioner of Income Tax, Mumbai - 6 [“learned PCIT”], for the assessment year 2020-21.
2. In this appeal, the assessee has raised the following grounds:
“1. On the fact and circumstances of the case as well as in Law, the Learned Principal Commissioner of Income Tax (PCIT) has erred in initiating proceedings U/s.263 of the Income Tax Act, 1961 (the Act) dated 03.03.2025 and passing an order U/s 263 of the Act, without considering the facts & Circumstances of the case.
2. On the fact and circumstances of the case as well as in Law, the Learned Principal CIT has erred in considering the order passed u/s. 143(3) r.w.s. 144B of the Income Tax Act, 1961
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