“CSR expenditure”

RELIANCE INDUSTRIAL INFRASTRUCTURE LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -3, MUBMAI

In the result, the appeal filed by the assessee is hereby allowed

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm M/S. Reliance Industrial Principal Commissioner Of Income Infrastructure Limited, Tax – 3, 5Th Floor, Nkm International House, Aayakar Bhavan, Vs. 178 Backbay Reclamation Marine Maharshi Karve Road, Lines Mumbai – 400 020 Mumbai – 400 020 Pan:Aaacr7637P (Appellant) : (Respondent)

invoked the revisionary jurisdiction u/s 263 of the Act for the reason that the assessee had debited an amount of Rs.35,00,000/- towards CSR expenditure and added the same to the total income in the computation of income as it is not allowable ... claimed 50% on the same amounting to Rs.17,50,000/- as CSR expenditure deductible u/s 80G of the Act, which was allowed by the Ld. AO during the appellate proceeding. The Ld. PCIT held that it is not an allowable deduction u/s 80G of the Act, thereby holding the assessment

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. RELIANCE RETAIL LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

being 50 percent thereof, under section 80G of the Act. 99. The assessee submitted before the Assessing Officer that although CSR expenditure is not allowable under section 37(1) in view of Explanation 2, the deduction in the present case was claimed not under section 37(1) but under section ... deduction under other provisions of the Act. The assessee further submitted that the Memorandum to the Finance (No. 2) Bill, 2014 itself indicates that CSR expenditure falling within the scope of other provisions would continue to be governed by those provisions. The assessee also argued that section 80G itself contains

RELIANCE RETAIL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 8(1)(1), MUMBAI

In the result, the appeal filed by the Revenue is dismissed,\nwhereas the appeal filed by the assessee is partly allowed

being 50 percent thereof, under section 80G of\nthe Act.\n99. The assessee submitted before the Assessing Officer that\nalthough CSR expenditure is not allowable under section 37(1) in\nview of Explanation 2, the deduction in the present case was\nclaimed not under section 37(1) but under section ... deduction\nunder other provisions of the Act. The assessee further submitted\nthat the Memorandum to the Finance (No. 2) Bill, 2014 itself\nindicates that CSR expenditure falling within the scope of other\nprovisions would continue to be governed by those provisions.\nThe assessee also argued that section 80G itself contains

ACIT CC 4 3, MUMBAI, MUMBAI vs. MAERSK LINE INDIA PRIVATE LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is allowed for statistical\npurposes

that as per assessment order\nthe assesseee company, falls under the applicability of Section 135 of the\nCompanies Act, 2013, and has duly incurred CSR expenditure in compliance\nwith the said provisions.\"\n9. \"Whether on the facts and in the circumstance of the case in law, the\nLd.CIT ... show cause as to why the deduction under section\n80G of the Act should not be denied. In response, the assessee submitted\nthat the CSR expenditure is not allowed in view of the explanation to section\n37 and hence, the same is disallowed and added back while computing the\ntotal

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social Responsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had debited this amount of CSR expenditure along with another amount of Rs. 2 lacs its profit and loss account. While computing the total income, it added back the same and claimed ... deduction u/s.80G being eligible under the said provision. According to the ld. Assessing Officer, since the donation made by the assessee relates to CSR expenditure, it is not allowable and thus, made the addition. In the first appeal, assessee by placing its reliance on various decisions of Coordinate Bench submitted

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social Responsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had debited this amount of CSR expenditure along with another amount of Rs. 2 lacs its profit and loss account. While computing the total income, it added back the same and claimed ... deduction u/s.80G being eligible under the said provision. According to the ld. Assessing Officer, since the donation made by the assessee relates to CSR expenditure, it is not allowable and thus, made the addition. In the first appeal, assessee by placing its reliance on various decisions of Coordinate Bench submitted

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social Responsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had debited this amount of CSR expenditure along with another amount of Rs. 2 lacs its profit and loss account. While computing the total income, it added back the same and claimed ... deduction u/s.80G being eligible under the said provision. According to the ld. Assessing Officer, since the donation made by the assessee relates to CSR expenditure, it is not allowable and thus, made the addition. In the first appeal, assessee by placing its reliance on various decisions of Coordinate Bench submitted

ACIT, CC-6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social Responsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had debited this amount of CSR expenditure along with another amount of Rs. 2 lacs its profit and loss account. While computing the total income, it added back the same and claimed ... deduction u/s.80G being eligible under the said provision. According to the ld. Assessing Officer, since the donation made by the assessee relates to CSR expenditure, it is not allowable and thus, made the addition. In the first appeal, assessee by placing its reliance on various decisions of Coordinate Bench submitted

ACIT, CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social\nResponsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had\ndebited this amount of CSR expenditure along with another amount of\nRs. 2 lacs its profit and loss account. While computing the total income,\nit added back the same and claimed ... deduction u/s.80G being eligible\nunder the said provision. According to the ld. Assessing Officer, since\nthe donation made by the assessee relates to CSR expenditure, it is not\nallowable and thus, made the addition. In the first appeal, assessee by\nplacing its reliance on various decisions of Coordinate Bench submitted

OVERSEAS INFRASTRUCTURE ALLIANCE(INDIA) PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social\nResponsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had\ndebited this amount of CSR expenditure along with another amount of\nRs. 2 lacs its profit and loss account. While computing the total income,\nit added back the same and claimed ... deduction u/s.80G being eligible\nunder the said provision. According to the ld. Assessing Officer, since\nthe donation made by the assessee relates to CSR expenditure, it is not\nallowable and thus, made the addition. In the first appeal, assessee by\nplacing its reliance on various decisions of Coordinate Bench submitted

OVERSEAS INFRASTRUCTURE ALLIANCE(INDIA) PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -6 , MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social Responsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had debited this amount of CSR expenditure along with another amount of Rs. 2 lacs its profit and loss account. While computing the total income, it added back the same and claimed ... deduction u/s.80G being eligible under the said provision. According to the ld. Assessing Officer, since the donation made by the assessee relates to CSR expenditure, it is not allowable and thus, made the addition. In the first appeal, assessee by placing its reliance on various decisions of Coordinate Bench submitted

OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMTIED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social Responsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had debited this amount of CSR expenditure along with another amount of Rs. 2 lacs its profit and loss account. While computing the total income, it added back the same and claimed ... deduction u/s.80G being eligible under the said provision. According to the ld. Assessing Officer, since the donation made by the assessee relates to CSR expenditure, it is not allowable and thus, made the addition. In the first appeal, assessee by placing its reliance on various decisions of Coordinate Bench submitted

OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMTIED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 6(2), MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social Responsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had debited this amount of CSR expenditure along with another amount of Rs. 2 lacs its profit and loss account. While computing the total income, it added back the same and claimed ... deduction u/s.80G being eligible under the said provision. According to the ld. Assessing Officer, since the donation made by the assessee relates to CSR expenditure, it is not allowable and thus, made the addition. In the first appeal, assessee by placing its reliance on various decisions of Coordinate Bench submitted

ACIT CC 6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social Responsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had debited this amount of CSR expenditure along with another amount of Rs. 2 lacs its profit and loss account. While computing the total income, it added back the same and claimed ... deduction u/s.80G being eligible under the said provision. According to the ld. Assessing Officer, since the donation made by the assessee relates to CSR expenditure, it is not allowable and thus, made the addition. In the first appeal, assessee by placing its reliance on various decisions of Coordinate Bench submitted

ACIT, CC-6(2), MUMBAI, MUMBAI vs. OVERSEAS INFRASTRUCTURE ALLIANCE (INDIA) PRIVATE LIMITED, MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

Rs.31,55,000/- u/s. 80G being 50% of Corporate Social Responsibility Expenditure (CSR) of Rs.63,10,000/-. Assessee had debited this amount of CSR expenditure along with another amount of Rs. 2 lacs its profit and loss account. While computing the total income, it added back the same and claimed ... deduction u/s.80G being eligible under the said provision. According to the ld. Assessing Officer, since the donation made by the assessee relates to CSR expenditure, it is not allowable and thus, made the addition. In the first appeal, assessee by placing its reliance on various decisions of Coordinate Bench submitted