Eligible CSR donations qualify for deduction where they are made...

Eligible CSR donations qualify for deduction where they are made to institutions covered by section 80G and are not contributions to Swachh Bharat Kosh or Clean Ganga Fund. Explanation 2 to section 37(1) prevents CSR expenditure from being claimed as business expenditure, but does not bar relief under other provisions. A statutory CSR obligation does not remove a payment's character as a donation when an eligible mode is voluntarily selected; the deduction was therefore granted. Dividend distribution tax on dividends paid to a UK holding company is limited to the beneficial rate under Article 11 of the India-UK tax treaty. Tax retained above that rate was required to be refunded.