Special Purpose Vehicle Charges Not CSR: Contributions to SPV Account Are Business Expenditure Under Explanation 1 to Section 37.

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....Addition under the head SPV charges - Whether part of Corporate Social Responsibility (CSR) activity - sale proceeds of overburden dumps outside sanctioned lease areas - In our view contributing 10%/15% to SPV account on account of Category ‘A’/ ‘B’ respectively, would be application of income, and therefore should be considered as expenditure incurred for carrying out its business activity. - Provisions of Explanation 1 to sec.37 will not apply to these payments. - AT....