50% Disallowance of Community Development Donations Challenged u/s 37(1) of Income Tax Act Pre-2014.

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....Expenditure on CSR - Disallowance of 50 % of the expenditure on account of the community development donation expenses under section 37 (1) - We do not find this “just‟ reason for confirming the disallowance. - Prior to 1/4/2014 no such disallowance was provided in the law....