P.C. Chandra Holding Pvt. Ltd. Vs. PCIT-2 (ITAT Kolkata)
Summary: The Kolkata Bench of the Income Tax Appellate Tribunal allowed the appeal of P.C. Chandra Holding Pvt. Ltd. and quashed the revision order passed by the Principal Commissioner of Income-tax under Section 263 of the Income-tax Act, 1961. The appeal concerned Assessment Year 2017-18 and challenged the assumption of revisionary jurisdiction by the Pr. CIT-2, Kolkata.
The assessee, engaged in the manufacture and sale of jewellery, filed its return on 30.10.2017 declaring total income of Rs. 25,16,27,420/-. The case was selected for scrutiny through CASS. Statutory notices were issued and served, and the assessee furnished the required details, information and documents in response to the questionnaire issued by the Assessing Officer. The assessment was completed under Section 143(3) on 03.12.2019 at the returned income.
Subsequently, the Pr. CIT called for the assessment records and initiated revisionary proceedings under Section 263 by notice dated 07.03.2022. Two issues were identified: first, deduction under Section 80G of Rs. 20,000/- in respect of a donation to Ramakrishna Mission, for which the Pr. CIT considered that evidence supporting the payment had not been produced; and second, deduction under Section 80G of Rs. 15,37,987/- claimed in respect of CSR expenditure, which the Pr. CIT considered inadmissible in view of Explanation 2 to Section 37.
