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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
RAJ KUMAR CHAUHAN, J
Millennium Developers Pvt. Ltd. – Appellant
Versus
PCIT-3 – Respondent
| Table of Content |
|---|
| 1. introduction of appeal and factual background. (Para 1 , 2) |
| 2. pcit's observations on ao's order and errors. (Para 3 , 10 , 11 , 12 , 13) |
| 3. assessee's grounds for appeal against pcit's order. (Para 4 , 5 , 6) |
| 4. court's reasoning on the appeal and error assessment. (Para 18 , 21) |
| 5. final decision on the appeal. (Para 22) |
ORDER
PER RAJ KUMAR CHAUHAN (J.M.):
1. This appeal is filed by the appellant/assessee against the order dated 21.03.2024 of Learned Principal Commissioner of Income Tax, Mumbai [hereinafter referred to as the “PCIT”], passed under section 253 of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] for the A.Y. 2017-18 wherein Ld. PCIT set aside the order of AO and directed to disallow the deduction u/s 80G of the Act in respect of donation claimed out of CSR expenditure.
2. The brief facts of the case are that, the assessee company is engaged in real estate business. The assessee filed its return of income for AY 2017- 18 on 31.10.2017 declaring total income of Rs. 9,66,52,230/- under normal provision and Rs. 10,13,32,715 u/s 115JB of the Act. The case was selected for scrutiny u/s 147 of the Act on the ground that assessee had debited an
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