PCIT Cannot Revise AO’s Enquiry on CSR & 80G Deduction: ITAT Mumbai

Morgan Stanley India Company Private Limited Vs PCIT (ITAT Mumbai) ITAT Mumbai has set aside the order passed by PCIT u/s 263 & restored the assessment order passed by AO. The Tribunal held that once AO had made inquiries on CSR expenditure & 80G deduction & had accepted the claim after due verification, PCIT could not invoke revisionary jurisdiction u/s 263 merely on the basis of Revenue Audit objection. The Assessee had filed return declaring total income of Rs.5347.41 crores which was processed u/s 143(1). Assessment was later framed u/s 143(3) r.w.s. 144C(13) on 29.07.2022 at R...