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Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
The note addresses whether CSR-related donations disallowed as business expenses under Explanation 2 to section 37(1) can nonetheless qualify for deduction under section 80G. The Tribunal applied the principle that Chapter VI-A deductions operate independently and held that a donation meeting the statutory conditions for charitable deductions and routed through banking channels is eligible under section 80G despite being excluded as a business deduction; accordingly, the departmental addition was deleted. The reasoning relied on coordinate-bench precedents and the donees' approval status under the statutory scheme.
The note addresses whether CSR-related donations disallowed as business expenses under Explanation 2 to section 37(1) can nonetheless qualify for deduction under section 80G. The Tribunal applied the principle that Chapter VI-A deductions operate independently and held that a donation meeting the statutory conditions for charitable deductions and routed through banking channels is eligible under section 80G despite being excluded as a business deduction; accordingly, the departmental addition was deleted. The reasoning relied on coordinate-bench precedents and the donees' approval status under the statutory scheme.
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