“CSR expenditure”

Fortrea Scientific Private Limited, Akruti Softech Park - Mumbai vs. PCIT - 3, Aayakar Bhavan - Mumbai

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

Bench: Ms. Kavitha Rajagopal, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

income out of which Rs. 30,79,318/- which is 50% of the said amount has been deducted u/s 80G of the Act as CSR expenditure which was paid as donation by the assessee company and the same was said to be allowed by the ld. AO in the assessment ... perusal of the above observations it is evident that the only issue that requires adjudication is whether the allowability of CSR expenditure as deduction u/s 80G claimed by the assessee and accepted by the ld. AO would tantamount to holding the assessment order to be erroneous and prejudicial

Chembond Chemicals Ltd, Mumbai vs. Principal Commissioner of Income Tax PCIT -6, Mumbai

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

reference to objections raised by internal audit perused the assessment records. Having examined the assessment records, Ld. PCIT noted that assessee has disallowed CSR expenditure u/s.37(1) of Rs.13,75,000/-. However, against this expenditure, assessee claimed deduction u/s.80G of Rs.5,10,228/-. He called for explanation from assessee ... 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

Rishabh Instruments Limited, Mumbai vs. PCIT -3, Mumbai

In the result, appeal filed by the assessee is allowed

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawalrishabh Instruments Ltd Vs. Pcit – 3 F-31, Satpur Midc, Nashik Room No. 612, 6Th Nashik – 422007 Floor, Aayakar Bhavan, Mk Road Pan/Gir No. Aaacr2228Q (Applicant) (Respondent)

passed the impugned order by holding that deduction under section 80G of the Act was erroneously allowed, since donation was in nature of CSR expenditure which is not voluntary in nature and thus not eligible for deduction. It was further held that the issue of section 80G/CSR was not discussed ... take up the first issue/question and after hearing the parties at length on this issue, we noticed that Ld. PCIT has held that since CSR expenditure is mandatory therefore the same cannot constitute a donation, which is voluntary and hence not eligible for deduction under section

Deutsche Investments India Private Limited, Mumbai vs. Deputy Commissioner of Income-Tax Circle- 4(2)(1), Mumbai, Mumabi

Appeal is allowed

Bench: Shri Pawan Singh (Jm) & Shri Omkareshwar Chidara (Am) Deutsche Investments India Pvt. Ltd. Dcit, Circle 4(2)(1) Block B1, Nirlon Knowledge Park, Off 6Th Floor, Room No. Western Express Highway, Goregaon Vs. 642, Aayakar East, Mumbai-400 063. Bhavan, M.K. Road Mumbai-400 020. Pan : Aaccd1765E Appellant Respondent

above: 2. The PCIT erred in denying deduction of Rs.55,00,000 claimed under section 80G of the Act, holding that it was CSR expenditure on which deduction under section 80G is not allowable. The Appellants crave leave to add to, amend, alter, vary, omit or substitute the aforesaid grounds

Wns Global Services Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 14(1)(2), Mumbai

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Smt. Renu Jauhriwns Global Services Vs. Pr. Commissioner Of Private Limited Income-Tax-6 Plant 11, Gate No. 4, Godrej Room No. 501, 5Th Floor & Boyce Complex, Aayakar Bhavan, Maharishi Piroshanagar, Lbs Marg, Karve Road, Mumbai Vikhroli West, Mumbai 400020. 400079 "थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacw2598L Appellant .. Respondent

Reliance has also been placed on various decisions in support of its claim that deduction u/s. 80G is allowable in case of CSR expenditure which is disallowed u/s. 37(1), if other conditions are fulfilled. Some of the decisions of the Mumbai Benches of the Tribunal cited ... expressed its intention clearly by bringing in restriction in respect of expenditure classified by an assessee company while claiming deduction under section 80G i.e. CSR expenditure P a g e | 7 ITA No. 3762/Mum/2025 Ay 2020-21 WNS Global Services Pvt Ltd related to Swachh Bharat Kosh and Clean Ganga

M/S. Unique Pharmaceutical Laboratories Limited, Mumbai vs. PCIT-8, Mumbai

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

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

challenging the revisional order passed under section 263 of the Act. 3. The Ld. AR argued and submitted that the assessee had incurred CSR expenditure amounting to Rs.30,00,000/-, out of which a sum of Rs.15,00,000/- was claimed as a deduction under section ... further contended that the CSR expenditure was not claimed as a business expense but specifically as a deduction under section 80G. Considering this claim, the Ld. PCIT invoked the provisions of section 263 of the Act. However, the said revisionary order was duly quashed by the coordinate bench

Netscribes Data & Insights Pvt Ltd, Mumbai vs. Principal Commissioner of (PCIT)-8, Mumbai

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am) Netscribes Data & Insights P.L. Pcit-8 Office No. 504, 5Th Floor 611, Aayakar Bhavan Lodha Supremus, Lower Parel Vs. M.K. Road Delisle Road, Mumbai-400013. Mumbai-400 020. Pan : Aaccn7742F Appellant Respondent

adjudicated in this case is whether the appellant company is eligible to claim deduction under section 80G which was part of Corporate Social Responsibility (CSR) expenditure claimed in the books of account. The Ld. AO has allowed the 80G deduction. The Ld. PCIT has issued a notice under section ... second argument is that the issue in question, whether the appellant is eligible for deduction under section 80G which was part of CSR expenditure of company. This issue was dealt with and decided in favour of the appellant company in several decisions of the Coordinate Benches of the ITAT Mumbai

JCIT OSD Circle 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, both the above stated appeals of the

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

that the sum paid by the assessee could not be considered as a 'donation' for the purpose of Section 80G of the Act. The CSR expenditure claimed as deduction u/s 80G was against the intention of law maker. So when the assessee paid an amount to an eligible entity under ... HDFC Bank Limited, Mumbai mandatory to comply with the provisions of the law. Further, CSR expenditure, being an application of income, was not incurred wholly and exclusively for the purposes of carrying on business. As the application of income is not allowed as deduction for the purposes of computing taxable

JCIT(OSD) Circle 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, both the above stated appeals of the

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

that the sum paid by the assessee could not be considered as a 'donation' for the purpose of Section 80G of the Act. The CSR expenditure claimed as deduction u/s 80G was against the intention of law maker. So when the assessee paid an amount to an eligible entity under ... HDFC Bank Limited, Mumbai mandatory to comply with the provisions of the law. Further, CSR expenditure, being an application of income, was not incurred wholly and exclusively for the purposes of carrying on business. As the application of income is not allowed as deduction for the purposes of computing taxable

JCIT(OSD) Circle 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, both the above stated appeals of the

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

that the sum paid by the assessee could not be considered as a 'donation' for the purpose of Section 80G of the Act. The CSR expenditure claimed as deduction u/s 80G was against the intention of law maker. So when the assessee paid an amount to an eligible entity under ... these scenarios too the expenditure would not have been voluntary but mandatory to comply with the provisions of the law. Further, CSR expenditure, being an application of income, was not incurred wholly and exclusively for the purposes of carrying on business. As the application of income is not allowed

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

In the result, both the above stated appeals of the

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

that the sum paid by the assessee could not be considered as a 'donation' for the purpose of Section 80G of the Act. The CSR expenditure claimed as deduction u/s 80G was against the intention of law maker. So when the assessee paid an amount to an eligible entity under ... HDFC Bank Limited, Mumbai mandatory to comply with the provisions of the law. Further, CSR expenditure, being an application of income, was not incurred wholly and exclusively for the purposes of carrying on business. As the application of income is not allowed as deduction for the purposes of computing taxable

Hdfc Bank Limited, Mumbai vs. The Deputy Commissioner of Income Tax - 2 (3) (1), Mumbai

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

that the sum paid by the assessee could not be considered as a 'donation' for the purpose of Section 80G of the Act. The CSR expenditure claimed as deduction u/s 80G was against the intention of law maker. So when the assessee paid an amount to an eligible entity under ... HDFC Bank Limited, Mumbai mandatory to comply with the provisions of the law. Further, CSR expenditure, being an application of income, was not incurred wholly and exclusively for the purposes of carrying on business. As the application of income is not allowed as deduction for the purposes of computing taxable

Asst. Commissioner of Income Tax -7(1)(1), Mumbai vs. Horizon Packs Pvt. Ltd., Mumbai

In the result, appeals by the revenue are dismissed

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

made towards CSR expenses which were subsequently claimed as donation deductible u/s 80G of the Act. The AO disallowed the same holding that the CSR expenditure are not voluntary but mandatory in nature hence not allowable u/s 80G of the Act. When the disallowance was agitated before ... applicability of Section 80G is concerned. 13. We find that the Co-ordinate Benches have taken a consistent view that CSR expenditure can be claimed as a deduction u/s 80G of the Act in the following cases:- Motilal Oswal Securities Ltd. (ITA No. 1795/Mum/2023, order dated 18.08.2023), Allegis Services India

Assistant Commissioner of Income Tax -7(1)(1), Mumbai vs. Horizon Packs Pvt. Ltd., Mumbai

In the result, appeals by the revenue are dismissed

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

made towards CSR expenses which were subsequently claimed as donation deductible u/s 80G of the Act. The AO disallowed the same holding that the CSR expenditure are not voluntary but mandatory in nature hence not allowable u/s 80G of the Act. When the disallowance was agitated before ... applicability of Section 80G is concerned. 13. We find that the Co-ordinate Benches have taken a consistent view that CSR expenditure can be claimed as a deduction u/s 80G of the Act आयकर अपीलीय अधिकरण INCOME TAX APPELLATE TRIBUNAL I.T.A. No. 5950 & 6096/Mum/2024 11 in the following cases:- Motilal

Anuh Pharma Limited, Mumbai vs. Principal Commissioner of Income Tax, Circle -5, Mumbai

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

amount was forming part of CSR expenses debited to P & L A/c. However, Tribunal has allowed the claim of the assessee by stating that, CSR expenditure is to be disallowed by new Explanation 2 to section 37(1), while computing Income under Head 'Income from Business and Profession'. Expenditure incurred