BHARAT SERUMS AND VACCINES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CIRCLE 15(1)(2), MUMBAI

PDF · subscribers
ITA 2780/MUM/2025Status: DisposedITAT Mumbai18 November 2025AY 2020-2021Bench: SHRI NARENDER KUMAR CHOUDHRY (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer's view in allowing deduction under Section 80G for CSR expenses was a legally sustainable view, supported by various judicial precedents. Therefore, the pre-requisite conditions for exercising jurisdiction under Section 263 were not met.

What were the facts?

The assessee claimed deduction under Section 80G for CSR expenditure. The PCIT initiated revision proceedings under Section 263, holding the assessment order allowing the deduction as erroneous and prejudicial to revenue. The assessee contended that the AO had duly considered the details and that CSR expenditure is allowable under Section 80G.

What were the issues?

Whether the PCIT validly invoked Section 263 to revise an assessment order allowing deduction for CSR expenditure under Section 80G, and whether CSR expenditure is allowable under Section 80G.

Which sections of the Income-tax Act were involved?

Section 263,Section 80G,Section 143(3),Section 142(1),Section 37(1)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(9)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI PRABHASH SHANKAR

For Appellant: Shri Manoj Mundra,AR
For Respondent: Shri Leyaqat Ali Aafaqui (Sr.DR)
Hearing: 01.10.2025Pronounced: 18.11.2025

आदेश की प्रयियलयि अग्रेयिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant 2. प्रत्यर्थी / The Respondent. आयकर आयुक्त / CIT 3. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT, 4.

More judgments on Section 263

All 13,616 judgments and leading authorities on Section 263 →

Recent GST High Court judgments

Search GST case law →