ACIT CC 4 3, MUMBAI, MUMBAI vs. MAERSK LINE INDIA PRIVATE LIMITED, MUMBAI

ITA 6166/MUM/2025Status: DisposedITAT Mumbai05 March 2026AY 2020-2117 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(A) had erred in granting relief on disallowances under Section 40(a)(i) and 40(a)(ia) without proper substantiation. The assessee's claim for deduction of CSR expenditure under Section 80G was also questioned.

What were the facts?

The Revenue appealed the CIT(A)'s order which granted relief to the assessee regarding disallowances under Section 40(a)(i) and 40(a)(ia) of the Income Tax Act. The assessee had made provisions for expenses and reversed them, with suo moto disallowances for non-deduction of TDS.

What were the issues?

Whether the CIT(A) erred in allowing provisions for expenses despite non-compliance with TDS provisions, and whether CSR expenditure is eligible for deduction under Section 80G.

Which sections of the Income-tax Act were involved?

Section 40(a)(i),Section 40(a)(ia),Section 206AA,Section 80G,Section 135

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, MUMBAI

Before: SHRI VIKRAM SINGH YADAV & SHRI SANDEEP SINGH KARHAIL

For Appellant: Shri Manish Kant, CA
For Respondent: Shri Virabhadra Mahajan, (Sr. DR)

PER SANDEEP SINGH KARHAIL, J.M. The Revenue has filed the present appeal against the impugned order dated 17.07.2025, passed under section 250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeal) – 52, Mumbai ["learned CIT(A)"], for the assessment year 2020-21. 2. In this appeal, the Revenue has raised the following grounds:

1.

"Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in granting relief to the assessee by allowing provisions for expenses under Section 40(a)(i) of the Income Tax Act, 1961, despite clear non-compliance with the provisions of C

The order continues below.

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