https://www.taxtmi.com/caselaws?id=786560 For assessment years before the 2022 amendment, disallowance under section 14A (and Rule 8D) cannot be invoked where no exempt income was earned, so the addition was deleted in favour of the assessee. Separately, Explanation 2 to section 37(1) disallowing CSR as business expenditure does not negate a distinct statutory deduction for donations; where the recipient fund/trust qualifies under the charitable-donation provision and is not one of the expressly excluded funds, the section 80G deduction is allowable, and the deduction was allowed in the assessee's favour. en-us Thu, 12 Feb 2026 00:00:00 +0530 Sat, 14 Feb 2026 08:29:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786560 For assessment years before the 2022 amendment, disallowance under section 14A (and Rule 8D) cannot be invoked where no exempt income was earned, so the addition was deleted in favour of the assessee. Separately, Explanation 2 to section 37(1) disallowing CSR as business expenditure does not negate a distinct statutory deduction for donations; where the recipient fund/trust qualifies under the charitable-donation provision and is not one of the expressly excluded funds, the section 80G deduction is allowable, and the deduction was allowed in the assessee's favour. Case-Laws Income Tax Thu, 12 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786560