https://www.taxtmi.com/article/detailed?id=12127 Explanation 2 to section 37(1) precludes treating CSR expenditure as business expenditure for purposes of computing business income, but that exclusion is confined to business-income computation and does not automatically negate the separate deductibility regime for donations. The maxim Expressio Unius Esl Exclusio Alterius supports reading specific restrictions in the donation-deduction provision as deliberate limits, so donations to funds expressly restricted when made as mandatory CSR are not deductible under the donation scheme, while donations over and above mandatory CSR may remain eligible for deduction. en-us Thu, 14 Dec 2023 08:33:19 +0530 Thu, 14 Dec 2023 08:33:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=12127 Explanation 2 to section 37(1) precludes treating CSR expenditure as business expenditure for purposes of computing business income, but that exclusion is confined to business-income computation and does not automatically negate the separate deductibility regime for donations. The maxim Expressio Unius Esl Exclusio Alterius supports reading specific restrictions in the donation-deduction provision as deliberate limits, so donations to funds expressly restricted when made as mandatory CSR are not deductible under the donation scheme, while donations over and above mandatory CSR may remain eligible for deduction. Articles Income Tax Thu, 14 Dec 2023 08:33:19 +0530 https://www.taxtmi.com/article/detailed?id=12127