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    <title>2021 (9) TMI 1405 - ITAT DELHI</title>
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    <description>CSR expenditure incurred on education, infrastructure, training, drinking water, sanitation and environment projects was held allowable as revenue expenditure under section 37(1), as the relevant assessment years predated Explanation 2, and the outlay was business-linked rather than capital or personal in nature; the disallowance was deleted. Disallowance under section 14A read with Rule 8D was also rejected because the Assessing Officer had not recorded the mandatory dissatisfaction with the assessee&#039;s claim and had not examined the books of account to identify expenditure attributable to exempt dividend income; mechanical invocation of Rule 8D was therefore unsustainable. The assessee succeeded on both issues and the additions were set aside.</description>
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      <title>2021 (9) TMI 1405 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=303314</link>
      <description>CSR expenditure incurred on education, infrastructure, training, drinking water, sanitation and environment projects was held allowable as revenue expenditure under section 37(1), as the relevant assessment years predated Explanation 2, and the outlay was business-linked rather than capital or personal in nature; the disallowance was deleted. Disallowance under section 14A read with Rule 8D was also rejected because the Assessing Officer had not recorded the mandatory dissatisfaction with the assessee&#039;s claim and had not examined the books of account to identify expenditure attributable to exempt dividend income; mechanical invocation of Rule 8D was therefore unsustainable. The assessee succeeded on both issues and the additions were set aside.</description>
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      <pubDate>Thu, 16 Sep 2021 00:00:00 +0530</pubDate>
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