https://www.taxtmi.com/caselaws?id=799501 Section 80G may allow a deduction for qualifying donations even when they form part of corporate social responsibility expenditure. Explanation 2 to section 37(1) disallows CSR expenditure in computing business income but does not impose a general bar on a specific donation deduction, except for donations expressly excluded under section 80G. Where statutory conditions are otherwise satisfied, CSR character alone does not defeat the claim. Given divergent judicial views, allowing the deduction constitutes a plausible and legally sustainable view. Revision under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests and cannot replace one permissible view with another; revision was therefore invalid. en-us Wed, 29 Jul 2026 00:00:00 +0530 Wed, 23 Sep 2026 08:48:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799501 Section 80G may allow a deduction for qualifying donations even when they form part of corporate social responsibility expenditure. Explanation 2 to section 37(1) disallows CSR expenditure in computing business income but does not impose a general bar on a specific donation deduction, except for donations expressly excluded under section 80G. Where statutory conditions are otherwise satisfied, CSR character alone does not defeat the claim. Given divergent judicial views, allowing the deduction constitutes a plausible and legally sustainable view. Revision under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests and cannot replace one permissible view with another; revision was therefore invalid. Case-Laws Income Tax Wed, 29 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799501