“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

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

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

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

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

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

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

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

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

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

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

ITA 1121/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

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

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

ITA 1120/CHNY/2019[2015-16]Status: DisposedITAT Chennai11 Mar 2024AY 2015-16

For Respondent: Shri. Nilay Baran Som, CIT

DCIT (Ltu) 2, Mumbai vs. Asian Paints Ltd, Mumbai

Appeal is allowed

ITA 841/MUM/2018[2013-14]Status: DisposedITAT Mumbai05 Mar 2024AY 2013-14

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailasian Paints Ltd. Asian Paints House 6A, Shanti Nagar, Santacruz (East) Mumbai 400 055 Pan – Aaaca3622K Appellant Asstt. Commissioner Of Income Tax Large Taxpayer Unit-2, Mumbai V/S

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Vachashpati Tripathi

Section 10(34)Section 142(1)Section 143(2)Section 143(3)Section 144C(3)Section 14ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL

Asian Paints Ltd, Mumbai vs. Asst CIT (Ltu) 2, Mumbai

Appeal is allowed

ITA 268/MUM/2018[2013-14]Status: DisposedITAT Mumbai05 Mar 2024AY 2013-14

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailasian Paints Ltd. Asian Paints House

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Vachashpati Tripathi

Section 10(34)Section 142(1)Section 143(2)Section 143(3)Section 144C(3)Section 14ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL

Ericsson India Global Services Private Limited, Delhi vs. DCIT, Circle-7(1), New Delhi

In the result, appeal is partly allowed for statistical purposes

ITA 1150/DEL/2022[2015-16]Status: DisposedITAT Delhi05 Mar 2024AY 2015-16

Bench: Sh. Saktijit Dey, Vice- & Sh. Pradip Kumar Kediaericsson India Global Vs. Dcit Services Private Ltd. Circle – 7(1) 18/17, 4Th Floor, Wea, New Delhi Pusa Lane, Dhaka House, Karol Bagh, Delhi-110 005 Pan No. Aacce 4175 D (Appellant) (Respondent) Assessee By Shri Vishal Kalra, Adv., Shri Ankit Sahni, Adv. & Shri Yishu Goel, Adv. Revenue By Shri Vizay B. Vasanta, Cit-D.R. Date Of Hearing: 28.02.2024 Date Of Pronouncement: 05.03.2024

Section 37(1)Section 80G

applicable only to ‘donation’ which is a ‘voluntary act’ on the part of the donor. He observed that since CSR expenditure has been incurred mandatorily in compliance of provisions of the Companies Act, it cannot be said to be voluntary and would not qualify for tax deduction under section ... CSR initiative of the assessee company which amounts to INR 22,81,29,964/-. It is observed that the assessee has duly disallowed CSR expenditure of INR 22,81,29,964/- debited to the statement of profit and loss under section 37 of the Act. DRP rejected the claim

DCIT (Ltu) 2, Mumbai vs. Asian Paints Ltd, Mumbai

Appeal is partly allowed

ITA 5934/MUM/2017[2012-13]Status: DisposedITAT Mumbai01 Mar 2024AY 2012-13

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Vachashpati Tripathi

Section 10Section 142(1)Section 143(2)Section 143(3)Section 144C(3)Section 14ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL

Asian Paints Ltd, Mumbai vs. Asst CIT Ltu, Mumbai

Appeal is partly allowed

ITA 5363/MUM/2017[2012-13]Status: DisposedITAT Mumbai01 Mar 2024AY 2012-13

Bench: Us.

Section 10Section 142(1)Section 143(2)Section 143(3)Section 144C(3)Section 14A

ASIAN PAINTS LTD. ITA NO.5363/MUM./2017 ITA NO.5934/MUM./2017 ("the Act") by the learned Commissioner of Income Tax (Appeals)-55

First Abu Dhabi Bank Pjsc, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-Circle 2(3)(1), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 3279/MUM/2023[2020-21]Status: DisposedITAT Mumbai27 Feb 2024AY 2020-21

Bench: Shri Amit Shukla & Shri Amarjit Singhfirst Abu Dhabi Bank Vs. Deputy Commissioner Of Pjsc, Unit No.1101 & Income-Tax (It), Circle 1201 Platina Building, C- 2(3)(1), Room No. 1614, 59, G Block, Bandra Kurla 16Th Floor, Air India Complex, Bandra East, Building, Nariman Point, Mumbai – 400051 Mumbai – 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaecn2845F Appellant .. Respondent Appellant By : Madhur Agarwal Respondent By : Anil Sant Date Of Hearing 07.02.2024 Date Of Pronouncement 27.02.2024 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Deputy Commissioner Of Income Tax, International Taxation, Circle 2(3)(1), Mumbai-2, Dated 20.07.2023 For A.Y. 2020-21. The Assessee Has Raised The Following Grounds Before Us: 1. Ground No. 1: The Learned Ao Has, On The Facts & Circumstances Of The Case & In Law, Erred In Initiating & Completing Assessment Proceedings Under Section 143(3) Of The Act Without Issuing A Valid Notice Under Section 143(2) Of The Act Ie, The Notice Under Section 143(2) Of The Act Dated 29 June 2021 For Initiating Assessment Was Issued By National Faceless Assessment Centre (Nafac) Instead Of Being Issued By The Learned Ao (I.E Jurisdictional Assessing Officer) 2. Ground No. 2:

For Appellant: Madhur AgarwalFor Respondent: Anil Sant

Section 143(2)Section 143(3)Section 153Section 155(18)Section 270ASection 80G

assessee has claimed an amount of Rs.49,06,031/- as donation provided to the educational institution and National Function Centre out of the total CSR expenditure of Rs.117,46,555/- and claimed deduction of Rs.24,53,016/- u/s 80G of the Act. We find that there is nowhere provided that

Golden Vats Private Limited, Chennai vs. ACIT, Central Circle 3(2), Chennai

In the result, the appeal filed by the assessee is allowed and the order passed by the Commissioner dated 14

ITA 416/CHNY/2023[2017-18]Status: DisposedITAT Chennai09 Jan 2024AY 2017-18

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.416/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) M/S. Golden Vats Private Limited Acit बनाम New No.272, 3Rd Floor, Central Circle-3(2), Avvai Shanmugam Salai, Chennai. / Vs. Gopalapuram , Chennai-600 086. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccg-9782-G (अपीलाथ"/Appellant) : (!"थ" / Respondent)

For Appellant: Shri T.S. Lakshmi Venkatraman (FCA)- Ld.ARFor Respondent: Shri V. Nandakumar (CIT)- Ld. DR

Section 143(3)Section 147Section 148Section 151Section 153CSection 263Section 263(1)Section 3Section 40

order on the ground that the assessment was reopened to make disallowance u/s 40(a)(ia) and also to make disallowance of donation and CSR expenditure for Rs.201.84 Lacs and Rs.21 Lacs respectively. The assessment order, though considered the issue of disallowance u/s 40(a)(ia), did not consider

Deputy Commissioner of Income Tax, Central Circle -3(2), Mumbai vs. Viraj Profiles Private Limited, Mumbai

In the result, appeal filed by the assessee is partly allowed as per above directions

ITA 2164/MUM/2023[2020-21]Status: DisposedITAT Mumbai20 Dec 2023AY 2020-21

Bench: Shri Narender Kumar Choudhry, Hon’Ble & Shri S. Rifaur Rahman, Hon'Bleviraj Profiles Pvt Ltd V. Dy. Cit - Central Circle- 3(2) (Formerly Known As Viraj Profiles Limited) Room No. 1923, 19Th Floor 1St Floor, Viraj Towers Air India Building Jn Of Andheri Kurla Road Nariman Point W.E. Highway, Andheri (E) Mumbai- 400021 Mumbai- 400093 Pan: Aabcv1740N (Appellant) (Respondent) Dy. Cit - Central Circle- 3(2) V. Viraj Profiles Pvt Ltd (Formerly Known As Viraj Profiles Limited) Room No. 1923, 19Th Floor 1St Floor, Viraj Towers Air India Building, Nariman Jn Of Andheri Kurla Road Point W.E. Highway, Andheri (E) Mumbai- 400021 Mumbai- 400093 Pan: Aabcv1740N (Appellant) (Respondent) Assessee Represented By : Shri. Mani Jain Department Represented By : Shri. Ujjawal Kumar Chavan

Section 250Section 37Section 80G

Ld.AR of the assessee submitted that during the year under consideration, the assessee incurred an expenditure of ₹.2,54,79,655/- on account of CSR expenditure which were made towards institutions eligible u/s 80G of the Act. Accordingly, the CSR expense was disallowed u/s 37 of the Act and deduction ... being 50% of eligible amount. In respect of the same, Assessing Officer observed that the intent of the legislature was never to allow the CSR expenditure which is expressly mentioned in section 37(1). The donation and CSR expenditure are two different modes of ensuring fund for public welfare; accordingly

Viraj Profiles Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Central Circle-3(2), Mumbai

In the result, appeal filed by the assessee is partly allowed as per above directions

ITA 1213/MUM/2023[2020-21]Status: DisposedITAT Mumbai20 Dec 2023AY 2020-21

Section 250Section 37Section 80G

ACIT-3(1)(1), Mumbai vs. Rustomjee Realty Pvt. Ltd., Mumbai

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 1585/MUM/2023[2020-21]Status: DisposedITAT Mumbai28 Nov 2023AY 2020-21

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Naresh KumarFor Respondent: Smt. Sanyogita Nagpal

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250

element of charity is missing in it. Accordingly, the AO disallowed the claim of deduction under section 80G of the Act towards CSR expenditure. 16. The learned CIT(A), vide impugned order, after noting that the assessee has disallowed CSR expenditure amounting to Rs. 11,00,000 under section ... Rs.5,50,000 which as per the appellant has been expended in compliance with the provisions of Companies Act, 2013 under head CSR expenditure. On perusal of the submission of appellant, it has been found that the A.O has disallowed the deduction claimed u/s 80G amounting

Societe Generale Securities India Pvt Ltd, Mumbai vs. The PCIT-4, Mumbai

In the result grounds raised by

ITA 1921/MUM/2023[2018-19]Status: DisposedITAT Mumbai20 Nov 2023AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Gagan Goyalsociete Generale Securities India Pvt. Ltd. Unit 1901, Tower-A, Peninsula Business Park, Ganpatrao Kadam Marg Lower Parel, Mumbai- 400013 Pan: Aaecs2909R ...... Appellant Vs. Pcit Room No. 629, 6Th Floor, Aayakar Bhavan, Maharishi Karve Road, Mumbai- 400020 ..... Respondent

For Appellant: Shri Niraj ShethFor Respondent: Shri Harshad S. Vengurlekar, CIT

Section 143(3)Section 263Section 263(1)Section 80G

notice u/s. 263 of the Act was issued by the office of Ld. PCIT on 01.03.2022 to examine the issue of allowability of CSR expenditure u/s. 80G of the Act, copy of notice issued by the office of Ld. PCIT u/s. 263 of the Act is reproduced as under ... assessment order and matter is restored to the file of AO for disallowing the claim of the assessee u/s. 80G of the Act on CSR Expenditure. 6 Societe General Securities India Pvt Ltd. Assessee being aggrieved with this order of Ld. PCIT u/s. 263 of the Act preferred this appeal

Supreme Buildestates Pvt Ltd, Madanganj- Kishangarh vs. DCIT Circle 2 Ajmer, Jaipur Road Ajmer

In the result, appeal of the assessee is allowed

ITA 495/JPR/2023[2020-21]Status: DisposedITAT Jaipur30 Oct 2023AY 2020-21

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri C.M. Agarwal (C.A.)For Respondent: Sh. Anup Singh (Addl. CIT) a

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144BSection 2Section 234BSection 37Section 80Section 80G

total income submitted by the assessee, it is found that the assessee has spent an amount of Rs. 7,50,00,000/- towards CSR expenditure and added back the same in the statement of total Income u/s 37 of the 4 Supreme Buildestates Pvt. Ltd. vs. DCIT Act while computing ... notice u/s 142(1) of the I.T. Act, 1961, dated 25.10.2021 the assessee was asked to explain as to why deduction u/s 80G on CSR expenditure of Rs. 17,16,540/- should not disallowed since CSR expenses is legal obligation of the company and not a voluntary donation In this

Savita Oil Technologies Ltd, Mumbai vs. ACIT, CC-8(4), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1258/MUM/2023[2017-18]Status: DisposedITAT Mumbai25 Oct 2023AY 2017-18

Bench: Shri Aby T. Varkey, Jm & Shri Amarjit Singh, Am आयकर अपील सं/ I.T.A. No.1258/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2017-18) Savita Oil Technologies बिधम/ Acit, Central Circle-8(4) Ltd. Room No. 659, Aayakar Vs. 66/67, Nariman Bhavan, Bhavan, M. K. Road, Nariman Point, Mumbai- New Marine Line, 400021. Mumbai-400020. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaafs3513J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Yogesh Thar/Chaitanya Joshi Revenue By: Shri Ram Krishna Kedia (Sr. Ar) Shri Virabhadra Mahanjan (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 04/07/2023/ (20/10/2023) घोषणा की तारीख /Date Of Pronouncement: 25/10/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax-50, Mumbai Dated 24.02.2023 For Assessment Year 2017-18. 2. The First Ground Of Appeal Of The Assessee Is As Under: - “1(A) The Appellant Submits That The Learned Commissioner Of Income-Tax (Appeals) [(“Cit(A)”)] Erred In Not Allowing The Claim Towards Expenditure On Account Of Gratuity Representing Amount Actual Paid To An Approved Gratuity Fund Of Rs.83,69,981/- Representing Employer'S Contribution. (B) The Appellant Submits That Cit(A) Failed To Appreciate That The Aforesaid Amount Of Rs.83,69,981/- Was Paid On Or Before The Due Date For Filing Its Return Of Income For Assessment Year 2017-18 To An Approved Gratuity Fund

For Appellant: Shri Yogesh Thar/Chaitanya JoshiFor Respondent: Shri Ram Krishna Kedia (Sr. AR)

Section 139(1)Section 143(3)Section 36(1)(v)Section 40A(7)Section 43BSection 80GSection 80I

action of the Ld. CIT(A) disallowing deduction u/s 80G of the Act amounting to Rs.22,75,000/- on the ground that these are CSR expenditure. 12. Brief facts are that this claim was also not made by the assessee in the original return of income; and the assessee filed ... then 50% of the donation is allowable expenditure [refer section 80G (1) (ii)]even if the assessee has included the expenditure as CSR Expenditure because there is no prohibition or restriction placed by the Parliament on such a donation even if shown as CSR expenditure. The reason for saying

DCIT- 3(4), Mumbai vs. M/S Reliance Industries Limited, Mumbai

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

ITA 2588/MUM/2022[2018-19]Status: DisposedITAT Mumbai18 Oct 2023AY 2018-19

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

profession. 11. This amendment will take effect from 1/04/2015 and will, accordingly, apply to assessment year 2015-16 and subsequent years. 12. Thus, CSR expenditure is to be disallowed by new Explanation 2 to section 37(1), while computing Income under the Head 'Income form Business and Profession'. Further, clarification ... shall be allowed if the same is incurred wholly and exclusively for the purposes of carrying on business or profession. As the CSR expenditure (being an application of income) is not incurred for the purposes of carrying on business, such expenditure cannot be allowed under the existing provisions of section

DCIT-3(4), Mumbai vs. M/S Reliance Industries Limited, Mumbai

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

ITA 2587/MUM/2022[2017-18]Status: DisposedITAT Mumbai18 Oct 2023AY 2017-18

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

Reliance Industries Limited, Mumbai vs. Dy Commissioner of Income Tax Circle-3(4), Mumbai

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

ITA 2318/MUM/2022[2017-18]Status: DisposedITAT Mumbai18 Oct 2023AY 2017-18

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

Reliance Industries Ltd., Mumbai vs. ACIT Circle 3(4), Mumbai

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

ITA 2317/MUM/2022[2018-19]Status: DisposedITAT Mumbai18 Oct 2023AY 2018-19

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

Teradata India Pvt Ltd, Grugram vs. DCIT Circle-3(1), Gurugram

Appeal of the revenue is allowed for AY 2018-19

ITA 2337/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Oct 2023AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Rajesh Kumar, CIT DR

Section 143(3)Section 37Section 80G

Companies Act, 2013 read with CSR rules thereon and as per the provisions of the Income Tax Act had also voluntarily disallowed the CSR expenditure while computing the taxable income. Since, the donee institutions are eligible institutions enjoying exemption u/s 80G of the Act, the assessee has claimed deduction