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CSR donations were held eligible for deduction where the claim was made under Chapter VI-A and not under business income provisions. The Tribunal found that the restriction in Explanation 2 to section 37(1) cannot be imported to deny a deduction otherwise admissible, and that only the express exclusions in section 80G(2) for donations to Swachh Bharat Kosh and Clean Ganga Fund made pursuant to CSR apply. Because the donation was not to either fund, the deduction was allowed. It also deleted the section 14A read with Rule 8D disallowance since no exempt income was earned, and treated the Finance Act, 2022 amendment to section 14A as prospective.
CSR donations were held eligible for deduction where the claim was made under Chapter VI-A and not under business income provisions. The Tribunal found that the restriction in Explanation 2 to section 37(1) cannot be imported to deny a deduction otherwise admissible, and that only the express exclusions in section 80G(2) for donations to Swachh Bharat Kosh and Clean Ganga Fund made pursuant to CSR apply. Because the donation was not to either fund, the deduction was allowed. It also deleted the section 14A read with Rule 8D disallowance since no exempt income was earned, and treated the Finance Act, 2022 amendment to section 14A as prospective.
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