September 2025
Can mandated spending also qualify for a tax deduction?
· Section 37(1) — expressly disallows CSR expenditure as a business deduction.
· Section 80G — permits deduction, subject to fulfilment of statutory conditions.
This divergence has fuelled years of litigation.
Judicial forums have generally leaned in favour of taxpayers. Yet, the Revenue continues to challenge such claims, often invoking arguments of “double benefit” and “lack of voluntariness”.
Read our detailed analysis here ⬇️
What emerges from this continuing controversy is a significant lesson: Corporate law and tax law, though aligned in their underlying purpose of fostering social responsibility, may at times pull in opposite directions when it comes to compliance and deductibility.
