REDSEER MANAGEMENT CONSULTING PRIVATE LIMITED,BENGALURU vs. DCIT, CIRCLE-5(1)(1), BANGALORE

ITA 697/BANG/2025Status: DisposedITAT Bangalore02 September 2025AY 2020-2113 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had voluntarily disallowed the CSR expense of Rs. 17 lakhs in its tax computation statement, meaning it was not claimed as a business expenditure under Section 37. Subsequently, the assessee claimed a deduction under Section 80G for 50% of the donation.

What were the facts?

The assessee company donated Rs. 17 Lakhs to Samarthanam Trust under its CSR scheme and claimed a deduction of Rs. 8,50,000/- under Section 80G of the Income Tax Act. The Assessing Officer (AO) and CIT(A) denied this deduction, holding that CSR expenditure is mandatory and not a voluntary donation.

What were the issues?

Whether a donation made under the Corporate Social Responsibility (CSR) scheme, which is voluntarily disallowed as a business expense, is eligible for deduction under Section 80G of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 80G,Section 37

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, B BENCH : BANGALORE

Before: SHRI LAXMI PRASAD SAHU & SHRI SOUNDARARAJAN K.

For Appellant: Shri Siddanna, CA
For Respondent: Shri Subramanian .S, JCIT-DR

PER SOUNDARARAJAN K., JUDICIAL MEMBER

This is an appeal filed by the assessee challenging the order of NFAC, Delhi dated 30/01/2025 in respect of the A.Y. 2020-21 and raised the following grounds.

“1. The order of the learned assessing officer is erroneous on facts and in law.

2.

The learned assessing officer erred in law by adding Rs.8,50,000/- to the returned income.

3.

The learned assessing officer/NFAC failed to appreciate the fact that the appellant company had voluntarily disallowed the CSR expense of Rs.17 lakhs in the tax computation statement.

4.

The learned assessing officer/NFAC failed to acknowledge that the appellan

The order continues below.

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