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August 2025

Where the assessee made donation to a foundation approved under section 80G in pursuance of its CSR obligations, it was entitled for deduction under section 80G.

By Jagdish T Punjabi, Chartered Accountant Devendra Jain & Aditya Bhatt, Advocates
Reading Time 3 mins

33. (2025) 175 taxmann.com 982 (Mum Trib)

Axis Securities Ltd. vs. PCIT

ITA No.: 2736/Mum/2025

A.Y.: 2020-21 Dated: 17.06.2025

Section 80G

Where the assessee made donation to a foundation approved under section 80G in pursuance of its CSR obligations, it was entitled for deduction under section 80G.

FACTS

The assessee was a company engaged in the business of broking, distribution of financial products etc. During the year, the assessee made donation to Axis Foundation of ₹1,93,66,947. It had classified the amount of donation as "Corporate Social Responsibility" (CSR) expenses under section 135 of the Companies Act, 2013 in its books of account and suo moto disallowed the same in computation of income in accordance Explanation 2 of section 37. However, it claimed the donation as deduction under section 80G. The said claim was duly disclosed in the computation of income and tax audit report, which was examined and allowed by the AO while passing the order of assessment under section 143(3).

PCIT invoked revision jurisdiction under sectio

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