Dismissing the appeal of the Revenue the High  Court held that the assessee had provided funds in discharge of its obligation as mandated by law on the advice of the Department of Public Enterprises and therefore, it could not be said that the obligation placed on the assessee by law was not connected wholly and exclusively to its business. There is nothing on record which would show that the assessee had directed investment of funds which were offered in fulfilment of discharge of its legal obligation in a capital asset. The Tribunal had concluded that the corporate social responsibility expenses incurred by the assessee were allowable under section 37. Explanation 2 appended to section 37(1) was not retrospective in nature. Followed, PCIT v. PEC LTD. (2023) 451 ITR 436 (Delhi)(HC). SLP of Revenue is dismissed.