2024 (8) TMI 1611

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....invalid. 2. The ld. PCIT has erred in that the assessment order dated 21 October 2021 passed u/s 143(3) r.w.s. 144C(3) r.w.s. 144B of the Act is erroneous and prejudicial to the interest of the revenue in setting aside the said order u/s 263 of the Act. 3. The ld. PCIT has erred in passing order u/s 263 of the Act directing the ld. AO to disallow the deduction u/s 80G of the Act amounting to INR 13,68,08,500/- in respect of donation claimed out of CSR expenditure. 4. The appellant craves leave to add, amend, modify, alter and/or delete any of the above grounds of appeal before or during the course of appeal." 2. Fact in brief is that return of income declaring total income of Rs. 5,55,71,68,580/- under normal provisions and Rs. 12,53....

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....urse of assessment, the assessing officer has made relevant enquiry on the issue of claim of deduction made by the assessee u/s 80G on the CSR expenditure and also referred the various documents filed by the assessee during the course of assessment proceedings. 4. On the other hand, ld. DR supported the order of ld. PCIT and also submitted that no deduction at all to be allowed in respect of CSR expenditure incurred by the assessee even deduction u/s 80G cannot be allowed. 5. Heard both the sides and perused the material on record. The case of the assessee was subject to scrutiny assessment u/s 143(3) of the Act and assessment order was passed on 21.10.2021. During the course of assessment, the assessing officer had issued notice u/s 142(....