ORDER

PER PAVAN KUMAR GADALE, JM:

The assessee has filed the appeal against the order of the Pr. Commissioner of Income Tax (Pr.CIT)-2, Mumbai passed u/sec 263 of the Act. The assessee has raised the fallowing grounds of appeal :

On the facts and in the circumstances of the case and in law, the Principal Commissioner of Income-tax- 2 ('Ld. PCIT') Grounds on validity of proceedings under section 263

1. erred in holding that the assessment order dated 8 April 2021 passed under section 143(3) read with section 143(3A) & (3B) of the Income Tax Act, 1961 ('the Act') is erroneous and prejudicial to the interests of the revenue. Grounds on Merits: Allowability of deduction under section 80G of the Act in respect of contributions towards Corporate Social Responsibility ('CSR') of Rs. 48,59,170:

2. erred in directing the Assessing Officer to conduct requisite enquiries in relation to allowability of deduction under section 80G in respect of donations made to eligible institutions and forming part of CSR contributions, and to