2025 (6) TMI 1128

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....PER NARENDRA KUMAR BILLAIYA [A.M.]: - This appeal by the assessee is preferred against the order of the Principal Commissioner of Income-tax, Mumbai-6 [hereinafter referred to as "PCIT"] dated 11.03.2025 pertaining to Assessment Year [AY] 2020-21. 2. The sum and substance of the grievance of the assessee is that the PCIT erred in assuming jurisdiction u/s 263 of the Income-tax Act, 1961 [her....

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....2022 framed u/s 143(3) r.w.s. 144B of the Act. 5. Assuming jurisdiction conferred upon him by the provisions of section 263 of the Act, the PCIT issued the following show cause notice to the assessee: "Subject: Notice for Hearing in respect of Revision proceedings u/s 263 of the THE INCOME TAX ACT, 1961-Assessment Year 2020-21. In this regard, a hearing in the matter is fixed ....

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....s. 16,72,93,660/-, 2. On perusal of assessment order u/s 143(3) r.w.s. 144B of the Act on 09.09.2022 it is observed that the order is erroneous and prejudicial to the interest of revenue for the following reasons: 2.1 On verification of the records, it is seen that that assessee has disallowed CSR expenditure of Rs. 15,00,000/- u/s 37(1) in the computation of income. However, aga....

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....ering the facts as discussed above. 4. In this connection, you are hereby given an opportunity of being heard and your case is fixed for hearing/making submission online on or before the date mentioned above. In case of non-compliance, it will be presumed that you have no objection to the proposed revision u/s 263 of the Act, of the assessment order passed by the Assessing Officer u/s. 14....