CSR donation deductions and treaty-limited dividend tax support relief for eligible contributions and UK shareholder distributions.

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....Eligible CSR donations qualify for deduction where they are made to institutions covered by section 80G and are not contributions to Swachh Bharat Kosh or Clean Ganga Fund. Explanation 2 to section 37(1) prevents CSR expenditure from being claimed as business expenditure, but does not bar relief under other provisions. A statutory CSR obligation does not remove a payment's character as a donation when an eligible mode is voluntarily selected; the deduction was therefore granted. Dividend distribution tax on dividends paid to a UK holding company is limited to the beneficial rate under Article 11 of the India-UK tax treaty. Tax retained above that rate was required to be refunded.....