UOI v. Dy. CIT (2023)102 ITR 235 (Bang) (Trib)

S.37(1): Business expenditure-Donation-Contribution-Ministry of Rural Development Instructing Public Sector Banks to lead Institutions in managing and running institutes-Allowable as deduction-Cenvat Credit–Unutilised Cenvat credit charged to profit and loss account-Not allowable as deduction-Bad debt written off-Matter remanded. [S. 36(1)(vii) 80G, Cenvat Credit Rules, 2004.]

The contribution had been made by the assessee to a foundation which had as its objects to set up training centres for educating and training people with a view to create awareness, develop local leadership among the community, development through self help, utilisation of local resources and talents. Allowable as deduction.  Unutilised Cenvat credit charged to profit and loss account, not allowable as deduction. Bad debt written off. Matter remanded (AY.2016-17)