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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

DCIT-2(3)(1), Mumbai vs. Kotak Mahindra Bank Limited, Mumbai

In the result, ground no. 1 raised by the revenue is

ITA 4056/MUM/2023[2012-13]Status: DisposedITAT Mumbai08 Aug 2024AY 2012-13

Bench: Shri Amit Shuklaand

For Appellant: Shri Biswanath Das, Ld. DRFor Respondent: Shri Faroog Irani, Ld. AR
Section 250Section 36(1)Section 36(1)(vii)Section 36(2)(ii)Section 36(2)(viia)

dated 20.06.2023, without appreciating Explanatory Notes to Finance No.2 Act, 2014, wherein it is highlighted: - a) CSR expenditure, being an application of income, is not incurred wholly &exclusively for the purposes of carrying on business. b) Hence on account of C.S.R. expenditure, no deduction is allowable u/s. 37 ofthe

ACIT, Circle 16(1), Delhi vs. Nucleus Software Exports Limited, Delhi

In the result, Appeals filed by the Revenue in ITA Nos

ITA 3214/DEL/2023[2020-21]Status: DisposedITAT Delhi06 Aug 2024AY 2020-21

Bench: DR. B.R.R. KUMAR (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 140Section 14ASection 80G

specifically mentions at two Clauses (viz, section 80G(2)(a)(iiihk) and (iiihl), i.e., contributions towards Swacha Bharat Kosh and Clean Ganga Fund), where CSR expenditure is not allowable as deduction under section 80G which itself a proven fact that legislature has clear contention that apart from these two clauses

ACIT, Circle 16 (1), Delhi vs. Nucleus Software Exports Limited, Delhi

In the result, Appeals filed by the Revenue in ITA Nos

ITA 2959/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Aug 2024AY 2017-18

Bench: DR. B.R.R. KUMAR (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 140Section 14ASection 80G

specifically mentions at two Clauses (viz, section 80G(2)(a)(iiihk) and (iiihl), i.e., contributions towards Swacha Bharat Kosh and Clean Ganga Fund), where CSR expenditure is not allowable as deduction under section 80G which itself a proven fact that legislature has clear contention that apart from these two clauses

Inter Gold (India) Private Limited, Mumbai vs. PCIT-2, Mumbai

In the result, appeal of the assessee is allowed

ITA 4400/MUM/2023[2018-19]Status: DisposedITAT Mumbai05 Aug 2024AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 115JSection 142(1)Section 143(3)Section 263Section 80G

course of assessment proceedings. It was further submitted that ld. AO has examined this issue and accepted that assessee has not claimed any CSR expenditure and accepted deduction u/s.80G. Assessee also referred to FAQs issued by Ministry of corporate affairs vide Circular No.01/2016 dated 12/01/2016 and also various decisions ... anomalous situation of Government subsidising the said expenditure incurred by the tax payers. The relevant extract of the Memorandum is as follows:- "13.2 CSR expenditure, being an application of income, is not incurred wholly and exclusively for the purposes of carrying on business. As the application of income

Bnp Paribas, Mumbai vs. Commissioner of Income-Tax (International Taxation) - 1, Mumbai

In the result, appeal of the assessee in ITA No

ITA 2521/MUM/2024[2017-18]Status: DisposedITAT Mumbai25 Jul 2024AY 2017-18

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Smt. Kavitha Rajagopal, Hon’Ble

For Appellant: Shri Niraj Sheth, A/RFor Respondent: Shri A.R. Dhyani, CIT, D/R
Section 143(3)Section 263Section 28GSection 37Section 80GSection 80G(5)

paid voluntarily to a donee, which is registered u/s 80G(5) of the Act. As expenditure for which deduction is claimed is purely CSR expenditure on which 80G deduction is not allowable as: • CSR expenditure by the assessee forms part of the mandatory requirement of the Companies Act and consequently

ACIT 3 3 1, Mumbai vs. Jamnagar Utilities and Power Pvt. Ltd., Mumbai

ITA 2117/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Jul 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mr. Nimesh Vora/Ms. MokashaFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 143(3)Section 147Section 148Section 37Section 37(1)Section 80G

claimed u/s 80G of the Act amounting to Rs.4,30,00,000/- holding that the same was in the nature of corporate social responsibility (CSR) expenditure incurred by the assessee, which is not allowable. 4. On further appeal, the Ld. CIT(A) deleted the disallowance in view of various decisions ... once own violation. The CSR not being voluntary rather it was legal mandate on the part of the assessee, the Assessing Officer held the CSR expenditure out of purview of the section 80G of the Act and accordingly he disallowed the claim of deduction of the assessee of Rs.4

Deloitte & Touche Assurance & Enterprise Risk Services India Private Limited, Hyderabad vs. DCIT, Circle-8(1), Hyderabad

In the result, both the appeals are allowed

ITA 342/HYD/2023[2018-19]Status: DisposedITAT Hyderabad18 Jun 2024AY 2018-19

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri SP. Chidambaram, ARFor Respondent: Shri Kumar Pranav, CIT-DR
Section 135Section 135(5)Section 30Section 37Section 37(1)Section 80GSection 80G(2)

under section 80G of the same, such a claim cannot be denied. 6. Learned AR further argued that there is no bar on claiming CSR expenditure as deduction if it falls within the scope of section 30 to 36 of the Act or qualifies for deduction under Chapter ... Circular No. 01/2015 dt. 21/01/2015 in fact supports the position of assessees inasmuch as it specifically provides that there is no estoppel to claim CSR expenditure as deduction if it is of the nature described in section 30 to 36 Page 3 of 13 ITA-TP Nos. 341 & 342/Hyd/2023

Deloittee Tax Services India Private Limited, Hyderabad vs. DCIT, Circle-8(1), Hyderabad

In the result, both the appeals are allowed

ITA 341/HYD/2023[2018-19]Status: DisposedITAT Hyderabad18 Jun 2024AY 2018-19

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri SP. Chidambaram, ARFor Respondent: Shri Kumar Pranav, CIT-DR
Section 135Section 135(5)Section 30Section 37Section 37(1)Section 80GSection 80G(2)

under section 80G of the same, such a claim cannot be denied. 6. Learned AR further argued that there is no bar on claiming CSR expenditure as deduction if it falls within the scope of section 30 to 36 of the Act or qualifies for deduction under Chapter ... Circular No. 01/2015 dt. 21/01/2015 in fact supports the position of assessees inasmuch as it specifically provides that there is no estoppel to claim CSR expenditure as deduction if it is of the nature described in section 30 to 36 Page 3 of 13 ITA-TP Nos. 341 & 342/Hyd/2023

Worley India Private Limited, Mumbai vs. Principal Commission of Income Tax 2, Mumbai

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

ITA 554/MUM/2024[2018-19]Status: DisposedITAT Mumbai03 Jun 2024AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

Section 143Section 143(3)Section 14ASection 263Section 37(1)Section 80G

CSR contributions, and to frame a fresh assessment order accodingly. 3. erred in not appreciating the fact that the provisions relating to disallowance of CSR expenditure have been introduced only in connection with allowability of deduction under section 37(1), and do not apply to allowability of deduction under section ... under:- 2.30 Your honours attention is invited to Memorandum of Finance Bill, 2015 wherein it was provided that expenditure on account of CSR expenditure will not be allowed as deduction u/s.80G of the Act for donation to Swatch Bharat Kosh and Clean Ganga fund only. Relevant extract

Gangaur Exports Private Limited, Jaipur vs. The PCIT-2, Jaipur

In the result grounds raised by the assessee are allowed and order of Ld

ITA 362/JPR/2023[2018-19]Status: DisposedITAT Jaipur30 May 2024AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sanjeev Kumar Mathur, CAFor Respondent: Sh. Arvind Kumar (CIT)
Section 135Section 142(1)Section 143(2)Section 143(3)Section 263Section 37Section 5Section 80GSection 80I

completing the assessment the faceless assessing officer has allowed the deduction under section 80G of the Act amounting to "67,50,000 being CSR expenditure added back from the total income. As per the explanation 2 to sub section (1) of section 37, any expenditure incurred by an assessee ... been passed by the Assessing Officer in a routine and perfunctory manner without examining the issue of deduction u/s 80G in respect of CSR expenditure. The order of the Assessing Officer is therefore liable to revision. Hence, the assessment order is set aside on the issue as discussed above

Interglobe Technology Quotient Private Limited, New Delhi vs. Assistant Commissioner Circle 10(1), New Delhi

ITA 95/DEL/2024[2020-2021]Status: DisposedITAT Delhi28 May 2024AY 2020-2021

Bench: Shri M. Balaganesh & Shri Anubhav Sharma[Assessment Year: 2020-21

Section 139(1)Section 143(3)Section 144BSection 199Section 250Section 251(2)Section 80G

AATE3346B TOTAL 2,75,89,740 1,37,94,870 4.1 Admittedly the donations made as part of CSR expenditure were suo-motu disallowed by the appellant under section 37(1) of the Act. However, the assessing officer disallowed the entire deduction claimed by the appellant on the ground that ... donations forming part of CSR expenditure is not allowable as deduction under section 80G of the Act. The CIT(A) though rightly observed that donations to the extent of Rs.1,19,87,840, being total of S.No. 4 & 7, in above column, were not paid as part of CSR expense

M/S Alubound Dacs India Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Circle 6(1)(1), Mumbai

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

ITA 3663/MUM/2023[2020-21]Status: DisposedITAT Mumbai27 May 2024AY 2020-21

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm M/S. Alubound Dacs India Private Dy. Cit, Circle-6(1)(1) Limited Mumbai 301, T V Industrial Estate, Vs. Behind Glaxo, Ahire Road, Worli, Mumbai-400 030

For Appellant: Ms. Simoni ChouhanFor Respondent: Shri Manoj Kumar Sinha
Section 135Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 154Section 246ASection 250Section 36(1)(va)Section 80G

exception for qualifying a donation for claiming u/s. 80G of the Act could also be an evidencing factor to substantiate that CSR expenditures which falls under the nature specified in section 30 to 36 of the Act are an allowable deduction u/s. 80G of the Act. 7 M/s. Alubound Dacs ... above observation, we deem it fit to hold that the assessee is entitled to deduction claimed u/s. 80G of the Act towards the CSR expenditure incurred by it. We, therefore, direct the ld. A.O. to allow the claim of the assessee subject to the condition that the assessee has satisfied

Dy. Commissioner of Income Tax, Circle-1(1), Pune vs. Credit Suisse Services (India) Private Limited, Pune

Appeal is dismissed in above terms

ITA 44/PUN/2024[2020-21]Status: DisposedITAT Pune15 May 2024AY 2020-21

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

For Appellant: Shri Rajendra AgiwalFor Respondent: Shri Ramnath P. Murkunde
Section 143Section 143(3)Section 37Section 80Section 80GSection 80G(2)(a)Section 80G(5)

section 80G of the Act. The institution to whom the Donations are made are duly registered under section 80G(5) of the Act • The CSR expenditure is not allowed only for the purpose of section 37 for computing business income. If such expenditure is otherwise allowable as deduction under other ... same cannot be disturbed. • The donations/expenditure made by the Appellant is towards women empowerment, education, environmental research etc. and forms part of CSR expenditure as per Schedule VII of the Companies Act, 2013. • The legislature has restricted the benefit only in two specific cases being ‘Swachh Bharat Kosh

Interglobe Enterprises Private Limited, New Delhi vs. ACIT Circle-10(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3914/DEL/2023[2020-21]Status: DisposedITAT Delhi08 May 2024AY 2020-21

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Pareek

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Mr. Waseem Arshad, CIT (DR)
Section 135Section 143(3)Section 144BSection 144CSection 37Section 37(1)Section 80G

section (2)(a) of section 80G of the Act are 3 I.T.A. No.2067/Del/2023 peculiar and provides for specific instances where CSR expenditure not eligible under s. 37, is also not to be allowed as deduction under s. 80G too. The relevant position of section

Keysight Technologies India Private Limited (Acquirer of Ixia Technologies Private Limited), Gurgaon vs. ACIT Circle 13(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2071/DEL/2023[2016-17]Status: DisposedITAT Delhi08 May 2024AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri Sudhir Pareekassessment Year 2016-17

For Respondent: Shri Rajesh Mahaja, Sr.DR
Section 135Section 143(3)Section 144CSection 37Section 37(1)Section 80G

iiihl) of the Act of sub-section (2)(a) of section 80G of the Act are peculiar and provides for specific instances where CSR expenditure not eligible under s. 37, is also not to be allowed as deduction under s. 80G too. The relevant position of section

Mankind Pharma Limited, Delhi vs. DCIT, Circle-1(1)(1), Meerut

In the result, the additional Ground No

ITA 2313/DEL/2022[2018-19]Status: DisposedITAT Delhi01 May 2024AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Rajesh Kumar, CIT (DR)
Section 143(3)Section 144BSection 144C(13)Section 153(3)Section 270ASection 35Section 80GSection 80I

appreciating that there is no bar in claiming deduction under section 80G of the Act in respect of donations made as part of CSR expenditure. Re: Disallowance of Deduction under section 35(2AB) amounting to Rs. 12,01,42,780/- 5. That the assessing officer erred on facts ... iiihl) of the Act of sub-section (2)(a) of section 80G of the Act are peculiar and provides for specific instances where CSR expenditure not eligible under s. 37, is also not to be allowed as deduction under s. 80G too. The relevant position of section

M/S. City Union Bank, Kumbakonam vs. DCIT, Circle - 2 (1), Trichy

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

ITA 672/CHNY/2020[2017-18]Status: DisposedITAT Chennai11 Mar 2024AY 2017-18

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

For Respondent: Shri. Nilay Baran Som, CIT

Lalitha, CA, submitted that the ld. Assessing Officer and CIT(A) were erred in confirming disallowance of CSR expenses without appreciating fact that, CSR expenditure voluntarily incurred by the assessee will not be covered by the Explanation (2) to section 37 of the Act. The Ld. Counsel for the assessee

DCIT Circle-2(1), Trichy vs. City Union Bank Limited, Kumbakonam

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

ITA 636/CHNY/2020[2017-18]Status: DisposedITAT Chennai11 Mar 2024AY 2017-18

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

For Respondent: Shri. Nilay Baran Som, CIT

Lalitha, CA, submitted that the ld. Assessing Officer and CIT(A) were erred in confirming disallowance of CSR expenses without appreciating fact that, CSR expenditure voluntarily incurred by the assessee will not be covered by the Explanation (2) to section 37 of the Act. The Ld. Counsel for the assessee

ACIT Circle 1, Kumbakonam vs. City Union Bank Ltd., Kumbakonam

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

ITA 1419/CHNY/2019[2016-17]Status: DisposedITAT Chennai11 Mar 2024AY 2016-17

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

For Respondent: Shri. Nilay Baran Som, CIT

Lalitha, CA, submitted that the ld. Assessing Officer and CIT(A) were erred in confirming disallowance of CSR expenses without appreciating fact that, CSR expenditure voluntarily incurred by the assessee will not be covered by the Explanation (2) to section 37 of the Act. The Ld. Counsel for the assessee

ACIT Circle 1, Kumbakonam vs. City Union Bank Ltd., Kumbakonam

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

ITA 1418/CHNY/2019[2015-16]Status: DisposedITAT Chennai11 Mar 2024AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

For Respondent: Shri. Nilay Baran Som, CIT

Lalitha, CA, submitted that the ld. Assessing Officer and CIT(A) were erred in confirming disallowance of CSR expenses without appreciating fact that, CSR expenditure voluntarily incurred by the assessee will not be covered by the Explanation (2) to section 37 of the Act. The Ld. Counsel for the assessee