The assessee-company is  engaged in the business of manufacturing, sale and trading of chemical fertilizers and chemical industrial products. The assessee claimed expenditure of Rs.1,75,036,756 in respect of contributions made to    various institutions. The Assessing Officer disallowed the claim.  Appellate Tribunal allowed the claim of the appellant Company . On appeal by the revenue    dismissing the appeal the Court held that  the assessee-company was a polluting company. The assessee-company was conscious of its social obligations towards society at large. The assessee-company was a Government undertaking and, therefore, obliged to ensure fulfilment of all the protective principles of State policy as enshrined in the Constitution of India. The moneys had been spent for various purposes and could not be regarded as outside the ambit of the business concerns of the assessee. The order passed by the Appellate Tribunal was just and proper and needed no interference in the present appeal. such disabling provision as long as the expenses, even in discharge of corporate social responsibility on voluntary basis, can be said to be “wholly and exclusively for the purposes of business”.

Court also held that   although the doctrine of res judicata is not applicable to Income-tax proceedings since each assessment year is independent of the other, where an issue has been considered and decided consistently in a number of earlier years in a particular manner the same view should continue to prevail in the subsequent years unless there is some material change in the facts. ( AY.2010-11)