CSR Grants Are Tied-Up Funds, Not Free Income of Charitable Trust

JM Financial Foundation Vs ITO (ITAT Mumbai) ITAT Mumbai on CSR Funds & Form 10: Substantive Justice Prevails Over Procedural Lapse Mumbai ITAT “F” Bench, in JM Financial Foundation v. ITO (Exemptions) (ITA Nos. 6557 & 6558/Mum/2025, AYs 2017-18 & 2018-19; order dated 29.12.2025), has set aside the NFAC orders and remitted the matter back to the AO for fresh consideration of CSR funds received by a charitable trust and the consequential requirement of filing Form 10. The Assessee-trust, registered u/s 12A, acted as an implementing agency for CSR activities of group companies an...