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    <title>2025 (5) TMI 790 - ITAT AHMEDABAD</title>
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    <description>Donation deduction and CSR expenditure operate in separate legal spheres; a donation to a fund that qualifies under the statutory donation-deduction regime remains eligible for deduction even if the payment arises from corporate social responsibility activities, and the taxpayers claim for such deduction was allowed accordingly. Expenditure relating to exempt income must be proportionately apportioned, including directors remuneration and employee costs, and a disallowance based on such apportionment was sustained where the taxpayer failed to supply a revised auditor certificate; a revised claim unsupported by an updated audit report was rejected.</description>
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