CHEMICAL PROCESS PIPING PVT LTD ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -6, MUMBAI

ITA 2953/MUM/2025Status: DisposedITAT Mumbai12 September 2025AY 2020-21Bench: SHRI OM PRAKASH KANT (Accountant Member), SHRI RAJ KUMAR CHAUHAN (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer (AO) was not required to conduct further inquiry as the issue of CSR expenditure being eligible for deduction under Section 80G was settled by various ITAT decisions. Therefore, the AO's order was neither erroneous nor prejudicial to the revenue.

What were the facts?

The assessee claimed a deduction under Section 80G for CSR expenditure. The PCIT initiated revision proceedings under Section 263, holding the assessment order erroneous and prejudicial to revenue. The assessee argued that the issue was settled by various tribunal decisions in their favor.

What were the issues?

Whether the PCIT correctly invoked Section 263 when the AO's assessment order was based on settled legal principles and no further inquiry was warranted.

Which sections of the Income-tax Act were involved?

Section 263,Section 80G,Section 37(1)

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Income Tax Appellate Tribunal, MUMBAI BENCH “C”, MUMBAI

For Appellant: Shri Nishit Gandhi & Shri
For Respondent: Shri R. A. Dhyani, Ld. DR
Pronounced: 12.09.2025

PER RAJ KUMAR CHAUHAN (J.M.):

1.

This appeal is filed by the appellant/assessee against the order dated 13.03.2025 of Learned Principal Commissioner of Income Tax, Mumbai [hereinafter referred to as the “PCIT”], passed under section 263 of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] for the A.Y. M/s. Chemical Process Piping Pvt. Ltd. 2020-21 wherein the assessment order u/s 143(3) r.w.s. 144B of the Act dated 12.09.2022 was set aside being erroneous and prejudicial to the interest of revenue by the Ld. CIT(A).

2.

The brief facts of the case are that, the assessee company is engaged in the

The order continues below.

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