M/S Santosh Foundation , Rampura Phul vs Commissioner Of Income Tax ... on 12 September, 2023
In our view, the fact that the CSR expenditure are not allowable
expenditure under section 37 of the Act is relevant only for the taxability of
the company incurring such expenditure. From the perception of the
assessee trust the amount received as donation whether will be eligible for
18
ITA No.286/Asr/2017
Santosh Foundation v. CIT
exemption under section 11 depends on the application of such fund for the
charitable activities by the trust only.