E Infochips Pvt. Ltd. vs. Principal Commissioner of Income Tax

Parties Involved

Facts Summary

The present appeal has been filed by the assessee, E Infochips Pvt. Ltd., against the order passed by the Principal Commissioner of Income Tax (PCIT) dated 18.03.2025 under Section 263 of the Income Tax Act, 1961. The appeal relates to the Assessment Year 2020-21. The assessee claims that the PCIT erred in exercising jurisdiction under Section 263 of the Act and that the assessment order passed under Section 143(3) of the Act was neither erroneous nor prejudicial to the interests of the Revenue. The assessee argues that the PCIT failed to consider that the deduction under Section 80G of the Act was deductible for computing total income and that the Assessing Officer had already examined the issue and allowed the deduction under Section 80G. The PCIT found the assessment order erroneous and prejudicial to the Revenue due to the claim of deduction under Section 80G, which was not admissible since the assessee had opted for the provisions of Section 115BAA of the Act. The assessee submitted that the claim of deduction under Section 80G was in accordance with the provisions of Section 115BAA of the Act.…

Legal Issues

• 1. Whether the Principal Commissioner of Income Tax erred in exercising jurisdiction under Section 263 of the Income Tax Act, 1961.
• 2. Whether the assessment order passed by the Assessing Officer was erroneous and prejudicial to the interests of the Revenue.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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