2026 (6) TMI 1389

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... For the Assessee : Sri Nikhil, CA For the Revenue : Sri Jeetendra Kumar- CIT DR ORDER PER PRASHANT MAHARISHI, VICE - PRESIDENT 1. This appeal by M/s. Sandisk India Device Design Centre Private Limited pertains to Assessment Year 2020-21 and is directed against the order dated 18 September 2025 passed by the National Faceless Appeal Centre, Delhi, dismissing the assessee's appeal agai....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e for filing the return of income under section 139(1). However, this issue is now covered against the assessee by the decision of the Hon'ble Supreme Court in Checkmate Services Private Limited. Accordingly, Ground No. 3 is dismissed. 4. The principal issue for consideration is whether the assessee is entitled to deduction under section 80G in respect of donations made as part of its Corporate....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ent was completed at Rs.1,98,42,57,072, as against the returned income of Rs.1,95,46,98,152. 6. Aggrieved by the assessment order, the assessee preferred an appeal before the learned CIT(A). The assessee raised two grounds, challenging the disallowance of deduction under section 80G and the disallowance of employees' contribution to Provident Fund amounting to Rs.1,95,25,472 on account of delay....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... assessee incurred CSR expenditure of Rs.2,04,66,899 during the relevant financial year and disallowed the same while computing its business income. It claimed deduction of Rs.1,02,33,452 under section 80G in respect of eligible donations forming part of that expenditure and furnished supporting receipts showing that the donee institutions were recognised under section 80G. 10. Though CSR expen....