BRUKER INDIA SCIENTIFIC PRIVATE LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX CIRCLE 4(1)(1), MUMBAI
What did the Tribunal hold?
The Tribunal held that claiming deduction under Section 80G for donations made from CSR expenditure is permissible if the conditions of Section 80G are met, as it is independent of the disallowance under Section 37(1) for CSR expenses. The PCIT's revisionary order was found to be erroneous as the Assessing Officer had taken a plausible view.
What were the facts?
The assessee claimed deduction under Section 80G for contributions made to the Prime Minister's National Relief Fund, which were part of its Corporate Social Responsibility (CSR) expenditure. The Assessing Officer allowed this deduction, but the Principal Commissioner of Income Tax (PCIT) revised the order, holding that CSR expenditure lacks voluntariness and thus cannot be claimed under Section 80G.
What were the issues?
Whether CSR expenditure, disallowed under Section 37(1), can be claimed as a deduction under Section 80G, and if the PCIT's revisionary order under Section 263 was justified.
Which sections of the Income-tax Act were involved?
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Cases cited in this judgment(2)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- ACIT v. Sikka Ports and Terminals Ltd.20 citing173 Taxmann.com 366 · 2025 · ITAT
- Commissioner of Expenditure Tax v. P.V.G. Raju17 citing101 ITR 465 · 1975 · SC
Income Tax Appellate Tribunal, ‘B’ BENCH
PER AMIT SHUKLA (J.M): The present appeal has been preferred by the assessee against the revisionary order dated 20/03/2025 passed by the learned Principal Commissioner of Income Tax, Mumbai, under section 263 of the Income-tax Act, 1961, in relation to the assessment year 2020-21. By the impugned order, the learned PCIT has set aside the assessment order dated 16/09/2022, on the ground that the Assessing Officer had 2 Bruker India Scientific Pvt. Ltd., wrongly allowed deduction under section 80G in respect of sums forming part of Corporate Social Responsibility (CSR) expenditure.
The assessee, a company engaged in the manufacture, dis
The order continues below.
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More judgments on Section 80G
- Savan Dayalal Ladani, Rajkot vs Assistant Commissioner of Income Tax-2(1)…ITA 575/RJT/2026[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Pareshbhai Savjibhai Khunt, Rajkot vs Income Tax Officer Ward - 2(2)(3), RajkotITA 842/RJT/2025[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Gillette India Limited, Mumbai vs Principal Commissioner of Income Tax, JaipurITA 1316/JPR/2026[2018-19]Status: Disposed16 Oct 2026AY 2018-19
- Global University Foundation, Hyderabad vs CIT(Exemption), HyderabadITA 777/HYD/2026[2026-27]Status: Disposed16 Oct 2026AY 2026-27
- Global University Foundation, Hyderabad vs CIT(Exemption), HyderabadITA 776/HYD/2026[2026-27]Status: Disposed16 Oct 2026AY 2026-27
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