https://www.taxtmi.com/caselaws?id=782722 ITAT Mumbai allowed the assessee's appeal and quashed the PCIT's order passed u/s 263. It held that although CSR expenditure is mandated u/s 135 of the Companies Act, the assessee retains discretion over the mode and recipient of such spending, and donations made thereunder are voluntary in nature. Relying on CBDT Circular No. 1/2015 and the clarification of the Ministry of Corporate Affairs, the Tribunal held that CSR expenditure otherwise qualifying u/s 80G is eligible for deduction, with the only bar being under s.37(1). Consequently, the assessment order allowing deduction u/s 80G on CSR donations was restored, and revision jurisdiction u/s 263 was held to be wrongly invoked. en-us Wed, 06 Aug 2025 00:00:00 +0530 Wed, 03 Dec 2025 08:57:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782722 ITAT Mumbai allowed the assessee's appeal and quashed the PCIT's order passed u/s 263. It held that although CSR expenditure is mandated u/s 135 of the Companies Act, the assessee retains discretion over the mode and recipient of such spending, and donations made thereunder are voluntary in nature. Relying on CBDT Circular No. 1/2015 and the clarification of the Ministry of Corporate Affairs, the Tribunal held that CSR expenditure otherwise qualifying u/s 80G is eligible for deduction, with the only bar being under s.37(1). Consequently, the assessment order allowing deduction u/s 80G on CSR donations was restored, and revision jurisdiction u/s 263 was held to be wrongly invoked. Case-Laws Income Tax Wed, 06 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782722