Assessee incurred CSR expenditure on activities like installation of handpumps, distribution of shoes, uniform etc. to school students, drought relief measures etc. The AO disallowed such expense on the ground that Explanation 2 to section 37(1) of the Act though inserted w.e.f 01.04.2015, to be clarificatory in nature. On appeal the Hon’ble Tribunal by referring to various other decisions held that the Explanation was retrospective. (AY.2004-05 to 2007-08)