Tribunal held that, Corporate social responsibility provision had been brought in companies Act 2013 and consequential amendment was brought to Income Tax Act u/s 37(1) by way of insertion of explanation w.e.f. 01.04.2015. When specific provision had been brought into statute for allowing such expenditure w.e.f. 01.04.2015 then prior to said provisions deduction in respect of expenditure incurred under Corporate Social Responsibility was not allowable unless and until expenditure was incurred wholly and exclusively for purpose of business of assessee. Accordingly the expenditure incurred by assessee for providing training to persons through Apparel Training & Development Centre in form of assistance of Rs. 2,000/- per trainee was in category of corporate social responsibility (CSR) had no direct connection/nexus with business activity of assessee. In absence of any provisions in Income Tax Act same could not be allowed prior to insertion of explanation 2 to section 37(1) w.e.f. 01.04.2015. ( AY.2009-10, 2010-11, 2011-12, 2012-13)
Rajasthan State Industrial Development & Investment Corp. Ltd. (2018) 195 TTJ 35 (Jaipur) (Trib.)
S. 37(1) : Business expenditure-Expenditure incurred by assessee for providing training to persons through Apparel Training & Development Centre in form of assistance of Rs. 2,000/- per trainee was in category of corporate social responsibility (CSR) was held not allowable unless and until expenditure was incurred wholly and exclusively for purpose of business of assessee.