“CSR expenditure”

Jewelex India Private Limited, Mumbai vs. DCIT Circle-14(1)(1), Mumbai

In the result, both the above appeals of the assessee

Bench: Shri Narender Kumar Choudhry

assessee had showed donations in three categories during the relevant previous year. First, an amount of Rs. 1,72,25,000/- was claimed towards CSR expenditure, of which it claimed 50% deduction under section 80G, amounting to Rs. 86,12,500/-. In addition, it made donations ... deduction under the head “business expenditure.” He reasoned that allowing deduction of the same expenditure under section 80G would defeat the statutory intent, since CSR expenditure lacked the element of voluntariness, which is the basic character of a donation. He held that the claim of deduction under section

Jewelex India Priavte Limited, Mumbai vs. DCIT Circle 14(1)(1), Mumbai

In the result, both the above appeals of the assessee

Bench: Shri Narender Kumar Choudhry

assessee had showed donations in three categories during the relevant previous year. First, an amount of Rs. 1,72,25,000/- was claimed towards CSR expenditure, of which it claimed 50% deduction under section 80G, amounting to Rs. 86,12,500/-. In addition, it made donations ... deduction under the head “business expenditure.” He reasoned that allowing deduction of the same expenditure under section 80G would defeat the statutory intent, since CSR expenditure lacked the element of voluntariness, which is the basic character of a donation. He held that the claim of deduction under section

Icici Securities Limited, Mumbai vs. Principal Commissioner of Income Tax, Mumbai -4, Mumbai

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

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

revision of deduction under section 80G amounting to ₹7,22,00,000/- in respect of donations forming part of Corporate Social Responsibility (“CSR”) expenditure; (v) the revision pertaining to deduction allowed for penalties paid to the stock exchange amounting to ₹64,64,367/-; and (vi) the revision relating to deduction ... deduction under section 80G amounting to ₹7,22,00,000/- was concerned, the learned Principal Commissioner held that the claim arose out of CSR expenditure incurred in compliance with section 135 of the Companies Act. Such expenditure, being mandatory in nature and lacking voluntariness, was held to be ineligible

Jewelex India Priavte Limited, Mumbai vs. DCIT Circle-14(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarjewelex India Private V/S. Deputy Commissioner Of Limited बनाम Income Tax, Circle – 401 Trade Centre, Bandra 14(1)(1), Aayakar Bhavan, Kurla Complex, Bandra Maharishi Karve Marg, (East), Mumbai – 400 098, Mumbai – 400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcj4523H Appellant/अपीलार्थी .. Respondent/प्रतिवादी

respect of donations aggregating to Rs. 10,87,43,245/- paid to eligible institutions/trusts classified as Corporate Social Responsibility(CSR) expenditure in the books of account. The AO made the disallowance holding that CSR expenses are expressly disallowable as per section 37(1) of the Act.Such expenses could ... ld.CIT(A) observed that the AO had clearly recorded that the donations fell into three categories: two of them, not being part of CSR expenditure, had already been allowed as deduction under section 80G. The dispute related only to the CSR outlay of the stated amount, of which deduction

DCIT, Circle 3 4, Mumbai vs. Tata Consultancy Services Limited, Mumbai

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

Bench: Shri Pawan Singh & Shri Girish Agrawal

Whether on facts and in circumstances of the case and in law, the Ld. CIT(A) erred in allowing deduction under Section 80G for CSR expenditure and the same needs to be set aside, and the disallowance made by the Assessing Officer during the course of assessment proceedings be upheld ... Whether on facts and in circumstances of the case and in low, the (d. CIT(A) erred in allowing deduction under Section 80G for CSR expenditure and the same needs to be set aside, and the disallowance made by the Assessing Officer during the course of assessment proceedings be upheld

Tata Consultancy Services Limited, Mumbai vs. Deputy Commissioner of Incometax 3(4), Mumbai

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

Bench: Shri Pawan Singh & Shri Girish Agrawal

Whether on facts and in circumstances of the case and in law, the Ld. CIT(A) erred in allowing deduction under Section 80G for CSR expenditure and the same needs to be set aside, and the disallowance made by the Assessing Officer during the course of assessment proceedings be upheld ... Whether on facts and in circumstances of the case and in low, the (d. CIT(A) erred in allowing deduction under Section 80G for CSR expenditure and the same needs to be set aside, and the disallowance made by the Assessing Officer during the course of assessment proceedings be upheld

Tata Consultancy Services Limited, Mumbai vs. Deputy Commissioner of Incometax 3(4), Mumbai

Bench: Shri Pawan Singh & Shri Girish Agrawal

IN THE INCOME TAX APPELLATE TRIBUNAL “H” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Jm Financial Foundation, Mumbai vs. ITO (Exemption)-Ward-1(4), Mumbai

In the result, appeal filed by assessee stands at for statistical purposes

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

towards CSR contribution is placed. He submitted that, the details of CSR funds received during the year under consideration along with details of the CSR expenditure carried on out of such CSR contributions supported by the acknowledgement of receipt have been furnished in the paper book which is not been

Jm Financial Foundation, Mumbai vs. ITO (Exem) Ward 1(4), Mumbai

In the result, appeal filed by assessee stands at for statistical purposes

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

towards CSR contribution is placed. He submitted that, the details of CSR funds received during the year under consideration along with details of the CSR expenditure carried on out of such CSR contributions supported by the acknowledgement of receipt have been furnished in the paper book which is not been

DCIT, Mumbai vs. Hubtown Limited, Mumbai

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

deduction under Section 80G would indirectly nullify the statutory disallowance under Section 37(1) and create an undue tax advantage, contradicting the principle that CSR expenditure should be an obligation of the company and not a means of tax reduction. 4 ITA Nos 1601 & 3038. /Mum/2025 Hubtown Limited ... shall be allowed if the same is incurred wholly and exclusively for the purposes of carrying on business or profession. 6.4.2 As the CSR expenditure, being an application of income, is not incurred for the purposes of carrying on business, such expenditures cannot be allowed under the existing provisions

Hubtown Limited, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 2(4), Mumbai

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

deduction under Section 80G would indirectly nullify the statutory disallowance under Section 37(1) and create an undue tax advantage, contradicting the principle that CSR expenditure should be an obligation of the company and not a means of tax reduction. 4 ITA Nos 1601 & 3038. /Mum/2025 Hubtown Limited ... shall be allowed if the same is incurred wholly and exclusively for the purposes of carrying on business or profession. 6.4.2 As the CSR expenditure, being an application of income, is not incurred for the purposes of carrying on business, such expenditures cannot be allowed under the existing provisions