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2026 Supreme(Online)(ITAT) 5034

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Vikram Singh Yadav, Accountant Member, Sandeep Singh Karhail, Judicial Member
Asst. Commissioner of Income Tax Central Circle -4(3) – Appellant
Versus
Maersk Line India Pvt. Ltd. – Respondent


Advocates:
For the Appellants/Petitioners: Shri Manish Kant, CA
For the Respondents: Shri Virabhadra Mahajan, (Sr. DR)

Table of Content
1. revenue's grounds challenge tds disallowances under sections 40(a)(i) and 40(a)(ia). (Para 2 , 3)
2. provisions for unidentified payees reversed; tds compliance verification required. (Para 4 , 5 , 6 , 7 , 8 , 9)
3. general grounds do not require adjudication. (Para 10)
4. csr expenditure disallowed under section 80g by ao. (Para 11 , 12 , 13)
5. csr expenses eligible for section 80g deduction if conditions met. (Para 14 , 15 , 16 , 17)
6. revenue appeal allowed for statistical purposes. (Para 18)

ORDER

PER SANDEEP SINGH KARHAIL, J.M.

The Revenue has filed the present appeal against the impugned order dated 17.07.2025, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeal) – 52, Mumbai [“learned CIT(A)”], for the assessment year 2020-21.

2. In this appeal, the Revenue has raised the following grounds: -

1. "Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in granting relief to the assessee by allowing provisions for expenses under Section 40(a)(i) of the Income Tax Act, 1961, despite clear non-compliance with the provisions of Chapter XVII-B of the Act, especially fai

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