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“CSR expenditure”

Business ExpensesSection 37Section 37449 judgments

The decision most relied on for CSR expenditure is JMS Mining (P.) Ltd. v. PCIT (130 Taxmann.com 118), cited in 93 judgments on BharatTax.

Leading authorities on CSR expenditure

JMS Mining (P.) Ltd. v. PCIT
130 Taxmann.com 118 · 2021 · ITAT
93
citing judgments

Donations made as part of Corporate Social Responsibility (CSR) expenditure are eligible for deduction under Section 80G if all conditions of Section 80G are satisfied. Such expenses are not automatically disallowed merely because they are CSR expenditure, in the absence of specific amendments to Section 80G similar to those in Section 37(1).

MOIL Ltd. v. CIT
396 ITR 244 · 2017 · High Court
74
citing judgments

Section 263 cannot be invoked to revise an assessment where the Assessing Officer has made an enquiry, examined the details submitted by the assessee, and applied their mind to be satisfied about the admissibility of a claim.

Hindustan Petroleum Corporation Ltd. v. DCIT
96 ITD 186 · 2005 · ITAT
36
citing judgments

Expenditure incurred by a Government undertaking towards implementation of the 20-point programme, as per specific directions of the Government, is allowable as business expenditure, even if voluntary and not statutorily mandated.

ACIT v. Jindal Power Ltd.
70 Taxmann.com 389 · 2016 · ITAT
30
citing judgments

Expenditure incurred voluntarily for Corporate Social Responsibility (CSR) purposes is not disallowed if Section 37(1) Explanation 2, which applies to statutory obligations, is not triggered. Additionally, Section 37 is prospective from AY 2015-16, making it inapplicable for AY 2013-14 disallowances.

Agilent Technologies (International) (P.) Ltd. v. ACIT
160 Taxmann.com 238 · 2024 · High Court
24
citing judgments

Corporate Social Responsibility (CSR) expenditure cannot be claimed as a deduction under Section 80G because it is a statutory mandate and lacks the voluntariness required for donations. This principle applies even when CSR contributions are made to funds like the Prime Minister's National Relief Fund or other eligible charitable institutions.

Ranbaxy Laboratories Ltd. v. Addl. CIT
39 SOT 17 · 2010 · ITAT
24
citing judgments

Expenditure incurred to promote business or bring goodwill to the assessee is allowable as a deduction. However, notional losses arising from issuing shares below market price are not deductible.

L&T Finance Ltd. v. DCIT
167 Taxmann.com 503 · 2024 · ITAT
24
citing judgments

Contributions made by a company for Corporate Social Responsibility (CSR) to a registered charitable institution can be treated as akin to corpus donations, potentially allowing for deduction under Section 80G of the Income Tax Act, provided other conditions are met.

Alubound Dacs India (P.) Ltd. v. DCIT
163 Taxmann.com 536 · 2024 · ITAT
24
citing judgments

Expenditure on Corporate Social Responsibility (CSR) activities is an allowable deduction under section 80G of the Income Tax Act, provided the conditions stipulated in section 80G are met, irrespective of being part of CSR expenditure.

Judgments citing CSR expenditure

Sundaram Fastners Ltd., Chennai vs. ITO, Corporate Ward-6(1), Chennai

The appeal stand partly allowed

ITA 2501/CHNY/2024[2020-21]Status: DisposedITAT Chennai15 Jan 2025AY 2020-21

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.2501/Chny/2024 (िनधा)रण वष) / Assessment Year: 2020-21) & 2. आयकरअपील सं./ It(Tp)A No.92/Chny/2024 (िनधा)रण वष) / Assessment Year: 2021-22) M/S Sundram Fasteners Limited Ito बनाम/ 98-A, 7Th Floor, Dr. Radhakrishnan Salai Corporate Ward-6(1) Vs. Mylapore, Chennai-600 004. Chennai "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaacs-8779-D (अपीलाथ"/Appellant) : (""थ" / Respondent) Shri Vikram Vijayaraghavan (Advocate) – Ld. Ar अपीलाथ"कीओरसे/ Appellant By : ""थ"कीओरसे/Respondent By : Shri A. Sasikumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 08-01-2025 घोषणाकीतारीख /Date Of Pronouncement : 15-01-2025 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Respondent: Shri A. Sasikumar (CIT) -Ld. DR
Section 115BSection 143(3)Section 144C(5)Section 14ASection 14A(2)Section 80GSection 92C

claimed as deduction U/s. 80G, AO erroneously disallowed Rs.3,22,41,778- which was not part of CSR expenditure at all. 2.3 The AO/DRP ought to have appreciated that there is no restriction in the Act that expenditure, when disallowed for CSR, cannot be considered ... Tribunal in support of the same. The assessee claimed that out of Rs.795.40 Lacs claimed as deduction u/s 80G, only Rs.472.99 Lacs pertain to CSR expenditure whereas the balance Rs.322.41 Lacs represents contributions to donee which are not part of CSR expenditure. However, Ld. AO held that the intention