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RU
CSR-Based Donations Eligible for Section 80G Deduction: ITAT Cochin
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The DRP partly reduced the transfer pricing adjustment but upheld the disallowance of the Section 80G claim relating to CSR donations.
Consequently, the AO passed the final assessment order disallowing the deduction under Section 80G and assessed the total income at ₹161.49 crore.
Before the Tribunal, the assessee contended that all statutory conditions for claiming deduction under Section 80G were fulfilled and that the donations were made to eligible entities.
It was further noted that while CSR expenditure is mandatory, the assessee retains discretion regarding the choice of recipient institutions.
Applying these principles, the Tribunal held that the AO was not justified in disallowing the deduction under Section 80G merely because the donations were sourced from CSR expenditure.