RELIANCE INDUSTRIAL INFRASTRUCTURE LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -3, MUBMAI

ITA 3751/MUM/2025Status: DisposedITAT Mumbai18 March 2026AY 2020-21Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the PCIT's invocation of Section 263 was not justified. A lack of detailed inquiry by the AO does not automatically make the assessment order erroneous if the claim itself is legally tenable, and CSR expenditure is eligible for deduction under Section 80G.

What were the facts?

The assessee claimed a deduction of Rs. 17,50,000 under Section 80G for donations made as part of CSR expenditure. The PCIT invoked revisionary powers under Section 263, holding the assessment order erroneous and prejudicial to revenue as the AO did not conduct proper inquiry.

What were the issues?

Whether the PCIT's invocation of revisionary powers under Section 263 was justified when the AO's alleged lack of inquiry did not make the assessment order erroneous or prejudicial to the revenue, and whether CSR expenditure is eligible for deduction under Section 80G.

Which sections of the Income-tax Act were involved?

Section 80G,Section 263,Section 143(2),Section 142(1),Section 143(3),Section 144B,Section 14A,Section 8D,Section 37(1),Section 135

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH, MUMBAI

Before: SHRI VIKRAM SINGH YADAV, AM

For Appellant: Ms. Moksha Mehta, AR
For Respondent: Shri Umashankar Prasad, CIT-DR
Hearing: 20.01.2026Pronounced: 18.03.2026

Per Kavitha Rajagopal, JM:

The appeal filed by the assessee challenges the order of the Learned Principal

Commissioner of Income Tax, Mumbai (‘Ld. PCIT’ for short) passed u/s 263 of the Income

Tax Act, 1961 (‘the Act'), pertaining to the Assessment Year (‘A.Y.’ for short) 2020-21 on the issue of deduction claimed u/s 80G of the Act on donations made as part of Corporate

Social Responsibility (‘CSR’ for short) expenditure amounting to Rs.17,50,000/-.

2.

Brief facts of the case are that the assessee company is engaged in infrastructure and support service activity and had filed its return of income for the

The order continues below.

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