2023 (10) TMI 405

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....fully convinced with the explanation offered, yet taking note of the fact that this appeal had been preferred by the Income Tax department under 260A of the Income Tax Act, 1961 (the Act) and we are required to consider as to whether any substantial questions of law arise for consideration, we exercise discretion in the matter and condone the delay in filing the appeal. The assessee is a company engaged in the business of mining iron ore and manganese. It filed its return of income for the assessment year under consideration i.e. A.Y. 2014-15 and the assessment was completed under Section 143(3) of the Act by order dated 29th December, 2006. During the course of assessment proceedings the Assessing Officer raised a query with regard to the....

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.... development of roads, construction of well, distribution of clothes, flood relief etc. to the local people as per the direction of the local administration and taking into consideration the welfare of the locality. Before the CIT(A) it was contended by the assessee that the periphery development expense was nothing but a corporate social responsibility (CSR) of the assessee company which was carrying out the mining operations in Joda, Orissa State. Further, it was mandatory for the mining industries to look after the development of the area in which mines were operating on account of creating employment opportunities, providing educational facilities to the children etc. Further, it was contended that the expenses incurred by the assessee ....