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INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
Makarand V. MahaDeokar, AM
Assessee – Appellant
Versus
Principal Commissioner of Income Tax, Ahmedabad-3 – Respondent
| Table of Content |
|---|
| 1. nature of the assessee's business and declared income. (Para 2 , 3) |
| 2. pcit's invocation of section 263 for alleged erroneous findings. (Para 4 , 5) |
| 3. issues surrounding foreign tax credits and csr deductions. (Para 10 , 11 , 12) |
| 4. assessing officer’s inquiries found sufficient to uphold original assessments. (Para 14 , 15) |
आदेश/ORDER
PER MAKARAND V.MAHADEOKAR, AM:
This appeal by the assessee is directed against the order passed by the Principal Commissioner of Income Tax, Ahmedabad-3 [hereinafter referred to as "the PCIT"], dated 30.03.2025, under section 263 of the Income-tax Act, 1961 ("the Act"), for the assessment year 2020–21, whereby the assessment order passed by the Assessing Officer under section 143(3) r.w.s. 144B of the Act dated 29.08.2022 was set aside for de novo assessment.
Facts of the Case
2. The assessee is a company engaged in the business of Information Technology Enabled Services and BPO support services and had, during the year under consideration, operations both in India and internationally. The assessee has a branch office in Manila, Philippines, through which it carried out certain business operations catering to global clients. The financial
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