“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

Lowes Services India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle 4(1)(1), Bangalore

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

ITA 1734/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore08 Sept 2025

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Chavali Narayan, ARFor Respondent: Dr. Divya K J, CIT(DR)(ITAT), Bengaluru

Section 143(1)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 36(1)(va)Section 80G

payment to Provident Fund [PF]. A further addition of Rs.76,48,794 was made by disallowing deduction u/s. 80G of the Act out of CSR expenditure. Thus, total income was Page 7 of 15 assessed at Rs.130,39,86,570. While computing the total income, the AO took the income ... withdrawn. The ld. AO held that assessee failed to submit complete documentary evidence and in the return of income assessee has shown it as CSR expenditure. Therefore deduction u/s. 80G of Rs.76,48,794 was disallowed. Page 14 of 15 27. The assessee filed objections before the ld. DRP which

Prudent Insurance Brokers Private Limited, Mumbai vs. PCIT-8, Mumbai

In the result, the appeal of the assessee stands allowed

ITA 3186/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Sept 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

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

learned PCIT, however, in exercise of his revisionary powers, observed that the expenditure for which deduction was claimed was nothing but CSR expenditure, and in terms of the statutory mandate of the Companies Act, 2013, such CSR expenses were not allowable as deduction under section ... organisations and contended that the Assessing Officer had duly verified all these details during the scrutiny assessment. It was further explained that while the CSR expenditure was suomoto disallowed in the computation of income, the donations, being voluntary contributions to institutions registered under section 80G, were independently claimed as deduction

Redseer Management Consulting Private Limited, Bengaluru vs. DCIT, Circle-5(1)(1), Bangalore

ITA 697/BANG/2025[2020-21]Status: DisposedITAT Bangalore02 Sept 2025AY 2020-21

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Siddanna, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 143(1)Section 143(2)Section 37Section 80G

Ld.CIT(A). The Ld.CIT(A) also without considering the issue in the right perspective had dismissed the appeal on the ground that the CSR expenditure incurred by the assessee is not voluntary but it is a mandatory one as per the Companies Act, 2013. 4. As against the said order ... gave the following findings. “5. The remaining amount of the disallowance was confirmed by NFAC on the ground that donations forming part of CSR expenditure is not allowable as deduction under section 80G of the Act. Same forms the basic controversy now. The assessing officer and CTT(A) disallowed

Bounteous Digital Private Limited, Chennai vs. Deputy Commissioner of Income Tax, Chennai

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

ITA 1600/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Aug 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1600/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Bounteous Digital Private Limited, Vs. The Deputy Commissioner Of Block A, 8Th Floor, Global Infocity Park Income Tax, No. 40, Mgr Salai, Perungudi, Corporate Circle 4(1), Chennai 600 096. Chennai. [Pan:Aaacl6079R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri A.R. Raghunathan, Ca (Virtual) ""थ" की ओर से/Respondent By : Shri C. Sivakumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.08.2025 घोषणा की तारीख /Date Of Pronouncement : 28.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.02.2025 Passed By The Addl/Jcit(A) – 10, Mumbai For The Assessment Year 2017-18. 2. The First Issue Raised By The Assessee Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Disallowance Of Csr Expenses In The Facts & Circumstances Of The Case.

For Appellant: Shri A.R. Raghunathan, CA (Virtual)For Respondent: Shri C. Sivakumar, Addl. CIT

Section 143(2)Section 30Section 36Section 37Section 37(1)Section 80G

Assessing Officer amounts to double disallowance which is erroneous in law. 6. The ld. DR Shri C. Sivakumar, Addl. CIT submits that the CSR expenditure, being an application of income, is not incurred wholly and exclusively for the purposes of carrying on business. He submits that as the application ... record. In the assessment order, we note that the Assessing officer disallowed the claim of deduction of salary to the CSR staff as CSR expenditure. On perusal of the impugned order, we note that the assessee was asked the details in respect of salary paid towards CSR expenses, which

Bruker India Scientific Private Limited, Mumbai vs. Principal Commissioner of Income Tax Circle 4(1)(1), Mumbai

In the result, the appeal of the assessee stands allowed

ITA 3793/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Aug 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 135Section 263Section 80GSection 80G(2)(iihk)Section 8G

Officer had 2 Bruker India Scientific Pvt. Ltd., wrongly allowed deduction under section 80G in respect of sums forming part of Corporate Social Responsibility (CSR) expenditure. 2. The assessee, a company engaged in the manufacture, distribution, sales, and services of scientific equipment, had filed its return of income on 12/02/2021 ... total income of ₹33,85,96,450/-. In its computation of income, it had suomoto disallowed an amount of ₹32,31,825/- towards CSR expenditure. Out of this, a sum of ₹28,02,082/- representing contribution to the Prime Minister’s National Relief Fund was claimed as deduction under section

Jay Chemical Industries Private Limited, Ahmedabad vs. PCIT, Ahmedabad-1, Ahmedabad

In the result, appeal of the assessee stands allowed

ITA 543/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad26 Aug 2025AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.543/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-21 Jay Chemical Industries The Pr.Cit बनाम/ Private Limited Ahmedabad-1 V/S. Jay House, Ahmedabad – 380 015 Near Panchvati Circle Ambawadi Ahmedabad – 380 006 "थायी लेखा सं./Pan: Aaacj 7628 J (अपीलाथ'/ Appellant) (!( यथ'/ Respondent) Assessee By : Shri Nimis Vayawala, Ar Revenue By : Shri R.P. Rastogi, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/06/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Preferred By The Assessee Is Against The Order Of Learned Principal Commissioner Of Income-Tax-1, Ahmedabad [Hereinafter Referred To As “Ld. Pcit” For Short] Dated 07/03/2025 Passed In Exercise Of His Revision Jurisdiction Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short] For Assessment Year (Ay) 2020- 2021. Jay Chemical Industries Pvt.Ltd.Vs. Pcit, Ahmedabad-1 Astt.Year 2020-21

For Appellant: Shri Nimis Vayawala, ARFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 135Section 263Section 37Section 37(1)Section 80G

assessee of Rs.6,73,40,611/-) u/s.80G of the Income Tax Act, 1961. The PCIT observed that a big portion of Corporate Social Responsibility (CSR) expenditure has been claimed as deduction u/s.80G of the Act, which otherwise was not an allowable expenditure u/s.37 of the Act. He, therefore, held that ... this case, has made donation to eligible institutions as provided under the relevant provisions of section 80G of the Act, however, out of CSR expenditure, which the assessee otherwise was mandatorily liable to incur u/s.135 of the Companies Act, 2013. We note that the issue as to whether the donation

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1082/KOL/2025[2021-22]Status: DisposedITAT Kolkata26 Aug 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR

Section 80Section 92C

against the order of learned CIT (A) allowing the deduction under Section 80G of the Act in respect of donation made under compulsory CSR expenditure which were incurred as donations to the eligible institutions under Section 80G of the Act. 015. The facts in brief are that the assessee during ... instances viz, sub-clauses (lihk) and (iiihl) of section 80G(2)(a), l.e., contributions towards Swacha Bharat Kosh and Clean Ganga Fund respectively, where CSR expenditure is not allowable as deduction w/s.80G. This implies that such prohibition does not apply to any other CSR expenditure when no such prohibition

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1081/KOL/2025[2020-21]Status: DisposedITAT Kolkata26 Aug 2025AY 2020-21

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR

Section 80Section 92C

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1080/KOL/2025[2018-19]Status: DisposedITAT Kolkata26 Aug 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR

Section 80Section 92C

Pramod Lakra, Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Balrampur Chini Mills Ltd, Kolkata

In the result all the four appeals of the revenue are dismissed

ITA 1079/KOL/2025[2017-18]Status: DisposedITAT Kolkata26 Aug 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsiyan, &For Respondent: Shri Praveen Kishore, DR

Section 80Section 92C

M/S. Industrial Solvents and Chemicals Private Limited, Mumbai vs. Principal Commissioner of -3, Mumbai

In the result, appeal of the assessee is allowed

ITA 3350/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Aug 2025AY 2020-21

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Revenue byFor Respondent: Shri R. A. Dhyani, CIT D/R

Section 143(3)Section 263Section 80G

showcause notice:- I.T.A. No. 3350/Mum/2025 3 5. The entire quarrel revolves around the claim of deduction u/s 80G of the Act in respect of CSR expenditure of Rs. 1,68,54,000/-. 50% of which i.e., Rs. 84,47,000/- was claimed as deduction u/s 80G of the Act. According ... raised by the ld. PCIT is a highly debatable issue as the Co-ordinate Benches of the Tribunal have taken a consistent view that CSR expenditure can be claimed as expenditure u/s 80G of the Act in the cases of Motilal Oswal Securities Ltd. (ITA No. 1795/Mum/2023, order dated

Deputy Commissioner of Income Tax, Circle-1, Aurangabad vs. Endurance Technoligies Limited, Aurangabad

In the result, all the appeals filed by the Revenue are dismissed

ITA 506/PUN/2025[2015-16]Status: DisposedITAT Pune25 Aug 2025AY 2015-16

Bench: Shri R. K. Panda & Ms. Astha Chandrasr No 1

For Appellant: S/Shri Nikhil Pathak andFor Respondent: S/Shri Amol Khairnar, CIT-DR and

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)Section 35Section 35(1)Section 80I

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

Deputy Commissioner of Income Tax, Circle-1, Aurangabad vs. Endurance Technologies Limited, Aurangabad

In the result, all the appeals filed by the Revenue are dismissed

ITA 1663/PUN/2024[2018-19]Status: DisposedITAT Pune25 Aug 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: S/Shri Nikhil Pathak andFor Respondent: S/Shri Amol Khairnar, CIT-DR and

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)Section 35Section 35(1)Section 80I

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

Deputy Commissioner of Income Tax, Circle-1, Aurangabad vs. Endurance Technologies Limited, Aurangabad

In the result, all the appeals filed by the Revenue are dismissed

ITA 1661/PUN/2024[2016-17]Status: DisposedITAT Pune25 Aug 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: S/Shri Nikhil Pathak andFor Respondent: S/Shri Amol Khairnar, CIT-DR and

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)Section 35Section 35(1)Section 80I

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

Deputy Commissioner of Income Tax, Circle-1, Aurangabad vs. Endurance Technologies Limited, Aurangabad

In the result, all the appeals filed by the Revenue are dismissed

ITA 1660/PUN/2024[2014-15]Status: DisposedITAT Pune25 Aug 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandrasr No 1

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)Section 35Section 35(1)Section 80I

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

Val Organics Pvt Ltd, Mumbai vs. Dy Comm. of Incomet Tax Circle-4(3)(1), Mumbai

In the result, appeal of the assessee stands allowed

ITA 2473/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Aug 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Val Organics Pvt. Ltd. Dy. Commissioner Of Income 4401, Kohinoor Square, B-Wing, Tax, Circle 4(3)(1), Mumbai. N.C. Kelkar Marg, Opp: Shiv Sena Vs. Room No. 649, 6Th Floor, Bhavan, Dadar West, Aayakar Bhavan, Maharashi Mumbai- 400028 Karve Road, Mumbai- 400020 Pan No. Aaacv 4456 E Appellant Respondent

For Appellant: Mr. Shekhar GuptaFor Respondent: Mr. Vivek Perampurna, CIT-DR

Section 135Section 143(3)Section 144BSection 263Section 37Section 80G

assessee’s claim of deduction under section 80G of the Act amounting to Rs. 64,43,500/-, being part of the Corporate Social Responsibility (CSR) expenditure aggregating to Rs. 1,19,09,024/-. The learned PCIT observed that expenditure incurred on CSR activities, being not purely voluntary in nature, does ... reply filed by the assessee, the learned PCIT held that, firstly, the Assessing Officer had failed to conduct requisite enquiry on the allowability of CSR expenditure vis-à-vis deduction under section 80G of the Act; and secondly, that in view of the mandatory nature of CSR obligations, such expenditure

Hemani Industires Limited, Mumbai vs. PCIT-6, Mumbai

In the result, appeal of the assessee is allowed, in terms of our aforesaid observations

ITA 2963/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Aug 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.2963/Mum/2025 "नधा"रण वष" / Assessment Year :2020-21 Hemani Industries Limited C-701-703, 7Th Floor, Neelkanth Business Park, R.N Road, Vidyavihar (West) Mumbai-400 086 Pan : Aaach1117Q

For Appellant: Shri Malav P. Sheth, CAFor Respondent: Shri Ritesh Mishra, Sr. DR

Section 115BSection 143(3)Section 263Section 80G

assessment order has observed as follows: “7. The submissions of the assessee on claim of deduction under section 80G on CSR expenditure have been duly considered and found unacceptable as CSR-related expenses, being statutorily mandated, cannot be considered "voluntary donations" under Section 80G, which was intended to incentivize voluntary ... Raju of Vizianagaram (1967) SCR (I) 1017C, which mandates that a donation must be voluntary to qualify for deduction under Section 80G. CSR expenditures are statutory obligations under the Companies Act, 2013, and thus lack the essential element 5 Hemani Industries Limited Vs. Pr. CIT-6, Mumbai of voluntariness. Additionally

Andhra Pradesh Power Generation Corporation Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle 1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 197/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2020-21

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

Section 143(1)(a)Section 143(3)Section 14ASection 37(1)Section 40

also made a disallowance of Rs. 2,30,27,863/- claimed by the assessee towards Corporate Social Responsibility (in short “CSR”) expenditure. Aggrieved by the various additions made by the Ld. AO, the assessee filed an appeal before the Ld. CIT(A). 5. The assessee reiterated the similar submissions before ... principle of consistency, the Ground No.4 raised by 17. the assessee is allowed. 18. Ground No.5 relates to disallowance of Corporate Social Responsibility (CSR) expenditure amounting to Rs. 2.30 Crs. The Ld. AR submitted that the company has incurred expenditure to comply with the provisions of section

Andhra Pradesh Power Generation Corporation Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 196/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 143(1)(a)Section 143(3)Section 14ASection 37(1)Section 40

Andhra Pradesh Power Generation Corporation Limited, Vijayawada vs. Deputy Commissioner of Income Tax, Circle-1(1), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 195/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2017-18

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI S BALAKRISHNAN HON’BLE (Accountant Member)

Section 143(1)(a)Section 143(3)Section 14ASection 37(1)Section 40