AXIS FINANCE LIMITED ,MUMBAI vs. DCIT 6(1)2, MUMBAI

ITA 2922/MUM/2025Status: DisposedITAT Mumbai16 June 2025AY 2020-21Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that CSR expenditure, even if mandatory, can be eligible for deduction under Section 80G if the other conditions of the section are met. The mandatory nature of CSR expenditure does not preclude it from being considered for deduction under Section 80G.

What were the facts?

The assessee, Axis Finance Limited, claimed a deduction under Section 80G for donations made to Axis Bank Foundation, which were also classified as CSR expenditure. The Assessing Officer (AO) and the Commissioner (Appeals) disallowed this deduction, holding that CSR expenditure is mandatory and not eligible for Section 80G deduction.

What were the issues?

Whether CSR expenditure is eligible for deduction under Section 80G of the Income Tax Act, despite being mandatory under the Companies Act.

Which sections of the Income-tax Act were involved?

Section 80G,Section 37,Section 135

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Before: SHRI SANDEEP GOSAIN & SHRI PRABHASH SHANKAR

For Appellant: Shri Madhur Agrawal,AR
For Respondent: Shri Aditya Rai (Sr. DR)
Hearing: 10.06.2025Pronounced: 16.06.2025

PER PRABHASH SHANKAR [A.M.] :- The present appeal is filed by the assessee against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”] pertaining to assessment order passed u/s. 143(3) of the Income-tax Act, 1961 [hereinafter referred to as “Act”] dated 28.09.2022 for the Assessment Year [A.Y.] 2020-21. P a g e | 2 A.Y. 2020-21 Axis Finance Limited, Mumbai

2.

The grounds of appeal are as under:-

1.

On the facts and in circumstances of the case and in law, the Hon'ble Comm

The order continues below.

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