MAHANSARIA ENTERPRISES PVT LTD,MUMBAI vs. PR. CIT, MUMBAI-5, MUMBAI

ITA 2158/MUM/2025Status: DisposedITAT Mumbai11 June 2025AY 2020-21Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI RAHUL CHAUDHARY (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the PCIT erred in invoking Section 263. The Assessing Officer (AO) had made detailed inquiries and allowed the deduction, and the AO's view was supported by various coordinate bench decisions.

What were the facts?

The assessee claimed deduction under Section 80G for Corporate Social Responsibility (CSR) expenses. The Principal Commissioner of Income Tax (PCIT) invoked Section 263, holding the assessment order allowing this deduction as erroneous and prejudicial to the revenue.

What were the issues?

Whether CSR expenses are eligible for deduction under Section 80G, and if the PCIT correctly invoked Section 263 to revise an assessment order where the AO had allowed such a deduction after inquiry.

Which sections of the Income-tax Act were involved?

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

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Cases cited in this judgment(9)Show list

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Income Tax Appellate Tribunal, MUMBAI “B” BENCH : MUMBAI

Before: SHRI VIKRAM SINGH YADAV & SHRI RAHUL CHAUDHARY

PER VIKRAM SINGH YADAV, A.M : This is an appeal filed by the assessee against the order of the Ld. Principal Commissioner of Income Tax, Mumbai-5 [„Ld.PCIT‟] u/s. 263 of the Income Tax Act, 1961 („the Act‟), dated 17-03-2025, pertaining to Assessment Year (AY) 2020-21, wherein the assessee has taken the following grounds of appeal:

“1. The PCIT erred in observing that the assessment order passed by the AO under section 143(3) r.w.s. 144B of the Act was erroneous and prejudicial to the interest of revenue and the

The order continues below.

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