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“application of income”

Judicial DoctrinesDiversion vs ApplicationDiversion vs Application1,603 judgments

The decision most relied on for application of income is Maxopp Investment Ltd. v. CIT (402 ITR 640), cited in 1,596 judgments on BharatTax.

Leading authorities on application of income

Maxopp Investment Ltd. v. CIT
402 ITR 640 · 2018 · Supreme Court
1,596
citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

CIT v. Max India Ltd.
295 ITR 282 · 2007 · Supreme Court
1,162
citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

Godrej & Boyce Manufacturing Company Ltd. v. DCIT
394 ITR 449 · 2017 · Supreme Court
683
citing judgments

Expenditure can only be disallowed under Section 14A if the income is exempt and not part of the total income. The Assessing Officer must first record dissatisfaction with the assessee's accounts or computation before proceeding to make a disallowance under Section 14A or applying Rule 8D.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Olari Little Flower Kuries (P.) Ltd. v. UOI
440 ITR 26 · 2022 · High Court
614
citing judgments

The fee under Section 234E of the Income-tax Act cannot be levied for defaults in filing TDS statements committed prior to June 1, 2015, as the provision for its levy became effective only from that date.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing application of income

Manav Seva Lok Kalyan Mahasangh, Nagpur vs. DCIT/ACIT Circle Exemptiom, Nagpur

In the result, appeal of the assessee is allowed

ITA 326/NAG/2025[2020-21]Status: DisposedITAT Nagpur26 Mar 2026AY 2020-21

Bench: Shri Pawan Singh & Shri Khettra Mohan Roymanav Seva Lok Kalyan Vs Dcit/Acit, Circle Mahasangh, H.No. 32, Teka Exemption, Nagpur Naka, Asi Nagar, Nagpur. Pan : Aabtm 1643 C Assessee Respondent Assessee By : Shri Kapil Hirani, Advocate Revenue By : Shri Pankaj Kumar, Cit-Dr Date Of Hearing : 25.02.2026 Date Of Pronouncement : 26.03.2026

For Appellant: Shri Kapil Hirani, AdvocateFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 11Section 12Section 12ASection 12A(1)(b)Section 139(1)Section 143(1)Section 250Section 44ASection 80G

processing of income. 6. Ld. Departmental Representative supported the orders of the lower authorities, but could not explain as to why the entire application of income has been ignored. 7. We have heard both the sides and perused the record placed before us. We note that assessee holds valid registration

Shree Patan Visha Shrimali Soni Gyanti Patan, Patan vs. The CIT(Exemption), Ahmedabad

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

ITA 2313/AHD/2025[NA]Status: DisposedITAT Ahmedabad26 Mar 2026

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: Na

Section 12ASection 12A(1)(ac)

aside to the file of Ld. CIT(E) with a direction to allow another opportunity to the assessee to explain the application of income of the Trust. 5. Per contra, Shri R P Rastogi, the Ld. CIT-DR, supported the order of Ld. CIT(E). He submitted that the assessee ... required to be examined vis- à-vis the actual expenses incurred by the assessee. In the absence of any categorical finding regarding application of income of the trust for the benefit of particular caste and community, we deem it proper to set aside the matter to the file

Kalptaru Vikash Samiti, Koteshwar Road vs. ITO, Exemption Ward Gwalior

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

ITA 557/AGR/2025[2013-14]Status: DisposedITAT Agra20 Mar 2026AY 2013-14

Bench: SHRI M. BALAGANESH, HON’BLE (Accountant Member), SHRI SUNIL KUMAR SINGH, HON’BLE (Judicial Member)

Section 11Section 12ASection 143(1)Section 154Section 250

exemption under section 11 of the Act by declaring Nil income. Due to technical mistakes in the ITR form, the proper head of application of income was not filled by the assessee. Factually, the assessee had indeed incurred revenue expenditure of Rs. 32,69,696/- towards its charitable objects ... still the total income was reflected in the said ITR only at Rs. Nil. This itself goes to prove that the figures of application of income has indeed been mentioned by the assessee elsewhere in the ITR but the same had not been captured in the ITR in Part

Reliance Industrial Infrastructure Limited, Mumbai vs. Principal Commissioner of Income Tax -3, Mubmai

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

ITA 3751/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm M/S. Reliance Industrial Principal Commissioner Of Income Infrastructure Limited, Tax – 3, 5Th Floor, Nkm International House, Aayakar Bhavan, Vs. 178 Backbay Reclamation Marine Maharshi Karve Road, Lines Mumbai – 400 020 Mumbai – 400 020 Pan:Aaacr7637P (Appellant) : (Respondent)

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 263Section 37(1)Section 80G

assessee’s case was selected for complete scrutiny under CASS for the following reasons: “1. Reduction in profit because of application of Income Computation & Disclosure Standards. 2. Large refund claimed out of advance tax (Business ITR). 3. Deductees have claimed tax deduction against salary by a TAN in their ITRs

Shanti Devi Jain Memorial Trust, Muzaffarnagar vs. ITO, Ward Exemption, Ghaziabad

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

ITA 1293/DEL/2018[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Years: 2013-14

Section 11(5)Section 12ASection 143(3)Section 234ASection 250(6)Section 80G

which prescribes specific mode of investment or deposit of funds. Further, the assessee has claimed the amount of Rs.16,03,916/- as application of income on account of purchase of fixed assets. It was explained that the amount of Rs.1,20,000/- represent amounts spent upon Insurance and accessories ... Rs.1,05,000/-. As the assessee could not furnish any evidence for Rs.1,20,000/-, the AO denied benefit on this account for application of income. 7. On the basis of above disallowance, the assessing officer has re- casted the Income-Expenditure account and the total application of funds

Bajaj Educational Society, Ludhiana vs. ITO Exemptions Ward, Jalandhar

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

ITA 225/ASR/2025[2018-19]Status: DisposedITAT Amritsar12 Mar 2026AY 2018-19

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: None
Section 11Section 143(3)Section 250Section 250(6)

salary. 3. That the Ld. C.I.T. (A), NFAC Delhi erred in law & facts in not treating the payment towards the salary as application of income. 4. That the Ld. C.I.T(A), NFAC Delhi erred in law & facts in sustaining the addition on flimsy grounds without affording reasonable opportunity of being

DCIT, Circle-1(1)(1), Ahmedabad vs. Amneal Pharmaceuticals Private Limited, Ahmedabad

In the result, the appeal of the Department is dismissed

ITA 2139/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Dhinal Shah, ARFor Respondent: Shri Dhinal Shah, AR
Section 135Section 37(1)Section 80GSection 80G(5)

Pharmceuticals Pvt. Ltd. Asst. Year –2022-23 - 3– cannot be regarded as voluntary donations. The Assessing Officer further observed that CSR expenditure represents application of income and if deduction under section 80G of the Act is allowed, it would amount to indirect allowance of CSR expenditure which has been specifically

The Bombay Hindu Burning and Burial Grounds Committee, Mumbai vs. ITO Exe Ward 2(4), Mumbai

In the result, the grounds of appeal raised by the assessee are allowed for statistical purpose

ITA 9324/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Mar 2026AY 2018-19

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 10Section 11Section 12ASection 143(1)Section 143(1)(a)Section 154Section 254(1)

appeal on merit. The ld. AR of the assessee submits that the assessee fulfilled all the condition to avail the benefit of application of income under section 11/12 of the Income Tax Act, 1961 (‘the Act’). 3 The Bombay Hindu Burning and Burial Grounds Committee 3. On the other hand ... inadvertence selected inappropriate provision in showing the status of assessee and mentioned Section 10(23C) instead of 12AA. The CPC not allowed the application of income under section 11/12, thereby disallowing all the expenses. It is matter of record that assessee filed application under section 154. The application of assessee

Richmond Educational Society, Noida vs. DCIT/ACIT Central Circle, Ghaziabad

ITA 4779/DEL/2025[2024-25]Status: DisposedITAT Delhi11 Mar 2026AY 2024-25

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

For Appellant: Revenue byFor Respondent: Shri Gaurav Jain, Adv
Section 12ASection 132Section 143(3)Section 2(15)

addition was made by the Learned AO in the assessment order on this issue since the Assessee had not claimed the same as application of income. Mr. Paramjit Gandhi was not even a related party in terms of section 13(3) of the Act at the relevant period ... submitted that the aforesaid transactions were not recorded in the books of accounts of the Assessee Society and accordingly not claimed as an application of income. It was also clarified that the said diary belonged to Shri Ashok Kumar Sharma, a private transporter and father of Shri Puneet Kumar Sharma

Deputy Commissioner of Income Tax, Yamunanagar vs. M/S the Ved Parkash Mukand Lal, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 833/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

Rs.3,86,28,412/- for the A.Y. 2006-07 investment in fixed deposits as application of income incomplete disregard. 2. The appellant craves leave to add or amend the grounds of appeal before this appeal is heard and disposed off. 1.2 It is admitted position that the issue in revenue ... assessee, inter- alia, contended that the investment made in Bank FDRs would be capital expenditure and is to be considered as an application of income. However, the said claim was rejected by Ld. AO considering the provisions of Sec. 11(1A). The Ld. AO also found that the assessee

DCIT vs. M/S the Ved Parkash Mukand Lal, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 832/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

Rs.3,86,28,412/- for the A.Y. 2006-07 investment in fixed deposits as application of income incomplete disregard. 2. The appellant craves leave to add or amend the grounds of appeal before this appeal is heard and disposed off. 1.2 It is admitted position that the issue in revenue ... assessee, inter- alia, contended that the investment made in Bank FDRs would be capital expenditure and is to be considered as an application of income. However, the said claim was rejected by Ld. AO considering the provisions of Sec. 11(1A). The Ld. AO also found that the assessee

The Ved Prakash Mukand Lal Educational Society, Yamunanagar vs. DCIT, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 825/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh10 Mar 2026AY 2006-07

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

Rs.3,86,28,412/- for the A.Y. 2006-07 investment in fixed deposits as application of income incomplete disregard. 2. The appellant craves leave to add or amend the grounds of appeal before this appeal is heard and disposed off. 1.2 It is admitted position that the issue in revenue ... assessee, inter- alia, contended that the investment made in Bank FDRs would be capital expenditure and is to be considered as an application of income. However, the said claim was rejected by Ld. AO considering the provisions of Sec. 11(1A). The Ld. AO also found that the assessee

The Ved Prakash Mukand Lal Educational Society, Yamunanagar vs. DCIT, Yamunanagar

In the result, the assessee’s appeals, for both the years, stand dismissed

ITA 824/CHANDI/2014[2005-06]Status: DisposedITAT Chandigarh10 Mar 2026AY 2005-06

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.824/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 2. आयकर अपील सं. / Ita No.825/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) The Ved Prakash Mukand Lal Dcit Educational Society Circle Yamuna Nagar बनाम/ Vs. (Radaur, Yamuna Nagar) Haryana C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / Ita No.833/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2005-06) & 4. आयकर अपील सं. / Ita No.832/Chandi/2014 (िनधा"रण वष" / Assessment Year: 2006-07) Dcit The Ved Prakash Mukand Lal Circle Yamuna Nagar Educational Society बनाम/ Haryana (Radaur, Yamuna Nagar) Vs. C/O Shri Tej Mohan Singh (Advocate) #527, Sector – 10D, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaatv-4812-B (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Tejmohan Singh (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Yamini (Cit) - Ld. Dr (Virtual)

For Appellant: Sh. Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Yamini (CIT) - Ld. DR (Virtual)
Section 11Section 11(2)Section 11(5)Section 12ASection 143(1)Section 143(3)Section 147

Rs.3,86,28,412/- for the A.Y. 2006-07 investment in fixed deposits as application of income incomplete disregard. 2. The appellant craves leave to add or amend the grounds of appeal before this appeal is heard and disposed off. 1.2 It is admitted position that the issue in revenue ... assessee, inter- alia, contended that the investment made in Bank FDRs would be capital expenditure and is to be considered as an application of income. However, the said claim was rejected by Ld. AO considering the provisions of Sec. 11(1A). The Ld. AO also found that the assessee

Verala Development Society, Sangli vs. Income Tax Officer (Exemption) Ward, Kolhapur

In the result, the appeal of the assessee is allowed

ITA 179/PUN/2026[2019-20]Status: DisposedITAT Pune10 Mar 2026AY 2019-20

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.179/Pun/2026 Assessment Year : 2019-20 Verala Development Society, Vs. The Income Tax Officer, 12 Kalanagar, Exemption Ward, Madhavnagar Road, Pb No.49, Kolhapur Sangli – 416 416 Maharashtra Pan : Aaatv1019N Appellant Respondent

For Appellant: Shri Sarang GudhateFor Respondent: Shri Dayanand Jawalikar
Section 11Section 143(1)Section 143(1)(a)

date but it was filed prior to filing of income-tax return. Based on these two facts, CPC denied the claim of application of income made by the assessee and assessed the income at Rs.14,40,688/-. Before ld.CIT(A) assessee partly succeeded. Now the assessee is in appeal before ... dated 25.04.2025. Respectfully following the same, I am inclined to hold that assessee’s claim of deduction u/s.11 of the Act for the application of income at Rs.11,12,999/- deserves to be allowed. Even otherwise, even if assessee is treated as an Association of Person (AOP) then also

Asst. Commissioner of Income Tax, Mumbai vs. Reliance Retail Limited, Mumbai

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

ITA 4244/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

Foundation. According to the Assessing Officer, Corporate Social Responsibility expenditure incurred under section 135 of the Companies Act lacked voluntary character and represented application of income. It was held that allowing deduction under section 80G would defeat the intent of Explanation 2 to section 37(1) of the Act. Accordingly ... Explanation 2 to section 37(1), read with the CBDT Circular No. 01/2015 dated 21.01.2015, makes it clear that CSR expenditure is an application of income and cannot be allowed as deduction, and that permitting deduction under section 80G would indirectly defeat that legislative intent. He also referred to Schedule

Reliance Retail Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 8(1)(1), Mumbai

ITA 3510/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

Foundation. According to the Assessing Officer, Corporate Social Responsibility expenditure incurred under section 135 of the Companies Act lacked voluntary character and represented application of income. It was held that allowing deduction under section 80G would defeat the intent of Explanation 2 to section 37(1) of the Act. Accordingly ... Explanation 2 to section 37(1), read with the CBDT Circular No. 01/2015 dated 21.01.2015, makes it clear that CSR expenditure is an application of income and cannot be allowed as deduction, and that permitting deduction under section 80G would indirectly defeat that legislative intent. He also referred to Schedule

Vyasa Vidya Mandiram, Coimbatore vs. CIT, Exemptions, Chennai

ITA 1287/CHNY/2025[-]Status: DisposedITAT Chennai09 Mar 2026
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

examine: 1. The objects of the trust; and 2. The genuineness of its activities. The authority is not required to examine the application of income in the manner of assessment proceedings. 9. We further note that the Id.CIT(E) relied heavily on Lok Shikshana Trust (supra). However, in the present

Vyasa Vidya Mandiram, Coimbatore vs. CIT, Exemptiions, Chennai

In the result, the appeals filed by the assessee-trust are allowed

ITA 1286/CHNY/2025[-]Status: DisposedITAT Chennai09 Mar 2026

Bench: Shri Manu Kumar Giri & Shris.R.Raghunatha

For Appellant: Mr. Y Sridhar, FCAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

activities. ITA 1286 & 1287 Chny 2025 Vyasa Vidya Mandiram Vs CIT E Chennai The authority is not required to examine the application of income in the manner of assessment proceedings. 9. We further note that the Id.CIT(E) relied heavily on Lok Shikshana Trust (supra). However, in the present case

Chitradurga Zilla Reddy Jana Sangh(R), Chitradurga vs. Income Tax Officer, Ward-1 Exemption, Hubli

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

ITA 1625/BANG/2025[2017-18]Status: DisposedITAT Bangalore05 Mar 2026AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Sri Shivanand Kalakeri, D.R
Section 11(1)Section 12ASection 143(1)Section 250

excess of expenditure incurred over the income of earlier years against the income of a later year will amount to application of income of such later year. The above is the position of law as held in the case of CIT v. Maharana of Mewar Charitable Foundation ... under s. 11, excess of expenditure in the earlier years can be adjusted against income of subsequent years and such adjustment would be application of income for subsequent years and that depreciation is allowable on the assets the cost of which has been fully allowed as application of income under

ACIT CC 4 3, Mumbai vs. Maersk Line India Private Limited, Mumbai

ITA 6166/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Manish Kant, CAFor Respondent: Shri Virabhadra Mahajan, (Sr. DR)
Section 135Section 143(2)Section 206ASection 250Section 40Section 80G

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 37 of the Income