VAL ORGANICS PVT LTD,MUMBAI vs. DY COMM. OF INCOMET TAX CIRCLE-4(3)(1), MUMBAI

ITA 2473/MUM/2025Status: DisposedITAT Mumbai25 August 2025AY 2020-21Bench: SHRI OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL ( (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the Assessing Officer (AO) had conducted sufficient enquiry and adopted a plausible view regarding the allowability of CSR expenditure under Section 80G, especially given divergent judicial opinions. Therefore, the PCIT's revisionary order under Section 263 was not justified.

What were the facts?

The assessee claimed a deduction of Rs. 64,43,500/- under Section 80G for Corporate Social Responsibility (CSR) expenditure. The Principal Commissioner of Income-tax (PCIT) initiated proceedings under Section 263, holding the assessment order erroneous and prejudicial to revenue as CSR expenditure is mandatory and not voluntary.

What were the issues?

Whether CSR expenditure is eligible for deduction under Section 80G, and whether the AO's assessment order was erroneous and prejudicial to revenue warranting revision under Section 263.

Which sections of the Income-tax Act were involved?

Section 80G,Section 263,Section 143(3),Section 142(1),Section 135

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Income Tax Appellate Tribunal, MUMBAI BENCH “F” MUMBAI

Before: SHRI OM PRAKASH KANT & MS. KAVITHA RAJAGOPAL

For Appellant: Mr. Shekhar Gupta
For Respondent: Mr. Vivek Perampurna, CIT-DR
Hearing: 08/07/2025Pronounced: 25/08/2025

PER OM PRAKASH KANT, AM

This appeal by the assessee is directed against revisional order dated 18.03.2025 passed by the Ld. Principal Commissioner of Income-tax, Mumbai-4 [in short ‘the Ld. PCIT’] for assessment year 2020-21, raising following grounds:-

“1. The learned Principal CIT has erred in law and on the facts of order the case in passing an u/s. 263 of the Income Tax Act holding that the assessment order is erroneous and prejudicial to the interest of revenue for allowing ineligible claim of deduction of Rs. 64,43,500/- u/s. 80G of the Income Tax Act.

Val

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