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2025 Supreme(Online)(ITAT) 3921

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Vikram Singh Yadav, A.M, Sandeep Gosain, J
GALLAGHER INSURANCE BROKERS PRIVATE LIMITED MUMBAI – Appellant
Versus
THE PRINCIPAL COMMISSIONER OF INCOME TAX-3 MUMBAI – Respondent


Advocates:
For the Appellants/Petitioners: Shri Mahadev P. Lohia
For the Respondents: Shri Swapnil Choudhary

Table of Content
1. nature of the appeal and basis for the pcit's order. (Para 1 , 2)
2. csr expenditures eligibility for deductions under section 80g. (Para 6)
3. the ruling in favor of the assessee's appeal and quashing of the pcit's order. (Para 10)

PER VIKRAM SINGH YADAV, A.M :

This is an appeal filed by the assessee against the order of the Learned Principal Commissioner of Income Tax-Mumbai-3 [„Ld.PCIT‟], dated 28-03-2025 passed u/s. 263 of the Income Tax Act, 1961 („the Act‟), pertaining to Assessment Year (AY) 2020-21.

2. During the course of hearing, the Ld.AR taken us through the findings of the Ld.PCIT, which are contained at paragraph No. 7.2 and 7.3 of the impugned order and the contents thereof read as under:

“7.2 DEDUCTION OF RS. 11,50,000/- CLAIMED AS DEDUCTION U/S 80G OF THE ACT:

On perusal of the submission, it is observed that the assessee has paid Rs. 23,00,000/- as EdelGive Foundation on 31.7.2020 within the extended time limit as per the Taxation and Other Laws(Relaxation of Certain Provisions) Ordinance, 2020 on 31.3.2020 and the CBDT’s Notification No. 35 of 2020, wherein the date for making deduction in respect of certain payments for AY 2020-21 has been extended

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