M/S. CYIENT INSIGHTS PRIVATE LIMITED ( FORMELY KNOW AS M/S. CITEC ENINGEERING INDIA PRIVATE LIMITED),HYDERABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE 1(1), HYDERABAD, HYDERABAD

The present appeal preferred by the Assessee is directed against the Order, dated 26/11/2025, passed by the Additional/Joint Commissioner of Income Tax (Appeals) – 2, Chennai [hereinafter referred to as the ‘CIT(A)’] whereby Learned CIT(A) had dismissed the appeal against the Rectification Order, dated 15/03/2023, passed under Section 154 read with Section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], for the Assessment Year 2017-2018. 2. The Assessee has raised following grounds of appeal:

The relevant facts in brief are that the Assessee is a company engaged in the business of providing Information Technology Enabled Services. For the Assessment Year 2017-2018, the Assessee filed its original return of income on 16/11/2017 declaring total income of INR.5,22,53,440/-. The case was selected for scrutiny assessment and Assessment Order, dated 11/03/2021, was passed under Section 2 Assessment Year 2017-2018

Being aggrieved, the Assessee carried the issue in appeal before Learned CIT(A). Vide Order, dated 26/11/2025, the Learned CIT(A) dismissed the appeal preferred by the Assessee concurring with the reasoning given by the Assessing Officer.

Now the Assessee has preferred the present appeal before the Tribunal challenging the denial of deduction of INR.9,30,000/- claimed by the Assessee under Section 80G of the Act in respect of CSR expenses.

We have given thoughtful consideration to do the rival submissions.

The issue that arises for consideration is whether the expenses incurred on CSR activity by way of donation made to charitable organizations would be eligible for deduction under Section 80G of the Act.

In the present case the Assessee had claimed deduction under Section 80G of the Act in respect of payment of (a) INR.4,30,000/- to Prime Minister Relief Fund (at the rate of 100%) and (b) INR.10,00,000/- towards Jan Vikas Society towards promoting children education (at the rate of 50%). Thus, deduction of INR.9,30,000/- was claimed by the Assessee under Section 80G of the Act in respect of donation of INR.14,30,000/-.

During the course of hearing the Learned Authorized Representative for the Assessee had placed reliance upon following decisions of the Co- ordinate Benches of the Tribunal cited before the Learned CIT(A) and stated in the statement of fact accompanying Form 35: - JMS Mining (P.) Ltd. v. Principal Commissioner of Income-tax,

We find identical view has been taken by the Mumbai Bench of the Tribunal in the case of M/s. Sonata Information Vs. Commissioner of Income Tax (Appeals): [ITA No.1402/Mum/2024, dated 05/11/2024]. In the aforesaid decision the Tribunal rejected the reasoning given by the Revenue for rejecting Assessee’s claim for deduction under Section 80G of the Act which was identical to the reasoning given by the Assessing Officer in the present case. After taking into consideration the provisions related to CSR contained in Section 135(5) of the Companies Act, 2013, relevant circulars issued by the Ministry of Corporate Affair and provisions contained in Explanation 2 to Section 37(1) of the Act [introduced vide Finance Act, 2014], the Co-Ordinate Bench of the Tribunal had held that the Assessee would be entitled to claim deduction under Section 80G of the Act in respect of CSR expenditure.

There is nothing on record to persuade us to take a different view either on facts or in law. Therefore, adopting the view taken by the Co- ordinate Benches of the Tribunal in favour of the Assessee, we hold that the Assessee was entitled to claim deduction of INR.9,30,000/- under Section 80G of the Act in respect of CSR Expenditure. Therefore, there was no mistake apparent on record in the Assessment Order, dated 11/03/2021, passed under Section 143(3) of the Act warranting

In result, in terms of paragraph 11 above, the present appeal preferred by the Assessee is allowed.

"धान आयकर आयु" / Pr.CIT 4. िवभागीय "ितिनिध ,आयकर अपीलीय अिधकरण ,मुंबई / DR, ITAT,

Mumbai गाड" फाईल / Guard file. 6. आदेशानुसार/ BY ORDER, स"ािपत "ित //// उप/सहायक पंजीकार /(Dy./Asstt.