IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH MUMBAI BEFORE HON'BLE JUSTICE (RETD.) C V BHADANG, PRESIDENT AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 3489/MUM/2025 Assessment Year: 2021-22 Asian Paints Limited Deputy Commissioner of Asian Paints House, Income-Tax, Circle 3(4), 6A & 6B Shanti Nagar, Mumbai Vakola Pipeline Lane Vs.

Santacruz (East), Mumbai - 400055 (PAN: AAACA3622K)

(Appellant) (Respondent)

Present for:

Assessee : Shri Madhur Agrawal, Advocate Revenue : Shri Rajesh Kumar Yadav, CIT DR Date of Hearing : 16.03.2026 Date of Pronouncement : 28.04.2026

O R D E R

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of ld. Pr.

Commissioner of Income Tax, Mumbai - 3, vide order no. ITBA/REV/F/REV5/2024-25/1074837702(1), dated 21.03.2025 passed against the assessment order by DCIT/ACIT, Circle-3(4), Mumbai, u/s. 143(3) r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 29.12.2022, for Assessment Year 2021-22.

2. Grounds taken by the assessee are reproduced as under:

“1. The Ld. PCIT (“Ld. PCIT”), erred in invoking and passing the order dated March 21, 2025 under section 263 of the Act (“impugned revision order”) without appreciating that revisionary proceedings under section 263 cannot be invoked unless the conjunctive conditions, that assessment order passed is erroneous in law and prejudicial to the interests of the revenue, are satisfied. The Appellant prays that the impugned revision order dated March 21, 2025 be quashed for non-satisfaction of preconditions for invoking provisions of section

263 of the Act.

2. The Ld. PCIT, erred in revising the order and directing the Assessing officer (“Ld. AO”) to make an addition of Rs.27.90 crores on account of provision for doubtful debts. The Appellant prays that the Ld. AO be directed to allow deduction of provision of doubtful debts amounting to Rs. 27.90 crores

3. The Ld. PCIT, erred in revising the order and directing the Ld. AO to make an addition of Rs.8.64 crores on account of tax on dividend received from specified foreign company u/s 115BBD of the Act without appreciating the fact that the Company has rightly claimed such amount as deduction under section 80M of the Act. The Appellant prays that the Ld. AO be directed to allow the deduction under section 80M of the Act of dividend received from specified foreign company.

4. The Ld. PCIT, erred in revising the order and directing the Ld. AO to make an addition of Rs.7.72 crores on account of festival and pooja expenses claimed under section 37(1) of the Act. The Appellant prays that the Ld. AO be directed to allow deduction under section 37(1) of the Act of festival and pooja expenses amounting to Rs. 7.72 crores.

5. The Ld. PCIT, erred in revising the order and directing the Ld. AO to make an addition of Rs.6.03 crores on account of taxes paid under protest claimed under section 43B of the Act. The Appellant prays that the Ld. AO be directed to allow a deduction under section 43B of the Act amounting to Rs. 6.03 crores.

6. The Ld. PCIT, erred in revising the order and directing to the Ld. AO make an addition of Rs.1.86 crores on account of claim of loss on account of GST credit reversal due to fire. The Appellant prays that the Ld. AO be directed to allow loss on account of GST credit reversal due to fire.

7. The Ld. PCIT, erred in revising the order and directing the Ld. AO to make an addition of Rs.0.50 crore on account of claim of exemption under section 54EC against capital gain under section 50C of the Act. The Appellant prays that the Ld. AO be directed to allow the claim of exemption under section 54EC of the Act amounting to Rs. 5 crore

2.1. There are seven grounds raised by the assessee out which ground no. 1 relates to assumption of jurisdiction by ld. PCIT for invoking revisionary proceedings u/s 263 and passing the impugned order thereon. Ground nos. 2 to 7 are in respect of direction given by the ld. PCIT to the ld. AO for making additio