2025 (8) TMI 690

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....pondent : Shri Ritesh Mishra, CIT DR ORDER PER ANIKESH BANERJEE (JM): The instant appeal of the assessee is filed against the order of the Learned Principal Commissioner of Income-tax (in short, 'the Ld.PCIT) passed under section 263 of the Income-tax Act, 1961 (in short, 'the Act') for Assessment Year 2020-21, date of order 20/03/2025. The impugned order emanated from the order of the As....

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....t as per the Companies Act, 2013 mandates the CSR expenses which is a statutory obligation not the voluntary. So the CSR expenses cannot be claimed as deduction under section 80G of the Act. So, the CSR Expenses was allowed by the Ld.AO amount to Rs. 13,90,000/- as deduction under section 80G of the Act is held as erroneous and prejudicial to the interest of the revenue. On invoking provisions of ....

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.... where at paras 9 & 10, the Ld.AO asked the specific question related to claim of expenses under section 80G of the Act. The assessee submitted details of expenses which is enclosed at APB page 70 and the relevant clarification related to the allowability of the deduction under section 80G of the Act which is annexed at APB pages 81 to 91. The Ld.AR relied on the order of the ITAT, Mumbai Bench....

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....plained by pursing the notice U/s 142(1) of the Act. We have given a thoughtful consideration to the order of the Ld. PCIT. We are of the considered view that the issue raised by the Ld. PCIT is a highly debatable issue as the Co-ordinate Benches of the Tribunal have taken a consistent view that CSR expenditure can be claimed as expenditure u/s 80G of the Act in the cases of WNS Global Services....