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Microlesson · 5-min read

Corporate Social Responsibility (Section 135)

# Corporate Social Responsibility (CSR) — Section 135

## 1. Applicability — Trigger Thresholds

A company (including a foreign company having a branch in India) must constitute a CSR Committee if, during the immediately preceding FY, it meets any one of:

  • Net worth ≥ ₹ 500 crores, OR
  • Turnover ≥ ₹ 1,000 crores, OR
  • Net profit (before tax) ≥ ₹ 5 crores.

### Definitions

Net worth = PUSC + Reserves out of profits + Securities Premium Accumulated losses, Deferred Expenditure, Misc. Expenditure not written off (as per audited B/S). Excludes revaluation reserves, write-back of depreciation and amalgamation reserves.

Net profit computed under Section 198 but excludes:

  • Profit from overseas branch.
  • Dividend received from an Indian company on which CSR is applicable.

## 2. Amount to be Spent on CSR

ItemRule
CSR spendAt least 2% of average net profits of immediately preceding 3 FYs (or of shorter period if company is younger).
Surplus from CSR activitiesNot treated as business profit. Use in the same project, OR transfer to Unspent CSR Account / Schedule VII fund within 6 months of FY end.
Excess spendIf a company spends in excess of the obligation (excess ≠ surplus), it may set off the excess against CSR obligation of the next 3 FYsBOD resolution required.

## 3. Failure to Spend — Unspent Amount Treatment

```

CSR amount not spent in FY

├── Ongoing Project ── Transfer to Unspent CSR Account within 30 days of FY end

│ └── Spend within 3 FYs per CSR Policy

│ └── Else transfer to Schedule VII fund within 30 days of completion of 3rd FY

└── Not an Ongoing Project ── Transfer to Schedule VII fund within 6 months of FY end

```

> Ongoing Project = project (other than one-time) not exceeding 3 years excluding the FY of commencement.

## 4. CSR on Capital Assets

A capital asset created/acquired through CSR spend must be held by:

  • A Section 8 company, OR
  • A Registered Public Trust / Society (with charitable objects and a CSR Registration Number), OR
  • The beneficiaries of the CSR project, OR
  • A Public Authority.

## 5. Administrative Overhead Cap

BOD must ensure admin overheads do not exceed 5% of total CSR expense for the FY. Direct costs of designing, implementing, monitoring & evaluating CSR projects are NOT admin overheads.

## 6. Penal Provisions for Default

DefaulterPenalty (lower of)
Company2× the amount required to be transferred to Schedule VII Fund / Unspent CSR A/c OR ₹ 1 crore
Officer in default1/10th of such amount OR ₹ 2 lakhs

## 7. CSR Committee

ItemRule
Composition3 or more directors, at least 1 independent director.
If independent director not required2 or more directors (no ID needed).
Private company with only 2 directorsThose 2 directors form the Committee.
Foreign company2 persons — (a) the person authorised to accept service of notice u/s 380(1), and (b) a person nominated by the foreign company.

### Exceptions

  • If CSR obligation ≤ ₹ 50 lakhsno CSR Committee required; BOD discharges its functions.
  • A company having amount in Unspent CSR A/c MUST constitute a CSR Committee.

### Duties of CSR Committee

  • Formulate & recommend CSR Policy to BOD (areas per Schedule VII).
  • Recommend the amount of CSR spend.
  • Monitor the CSR policy.

### Annual Action Plan (recommended by Committee to BOD)

  • List of projects in Schedule VII areas.
  • Manner of execution (itself / through Section 8 company etc.).
  • Utilisation of funds & implementation schedule.
  • Monitoring & reporting mechanism.
  • Details of need and impact assessment.

BOD may alter the plan anytime on the Committee's recommendation.

### Duty of BOD

After considering Committee's recommendations, BOD shall:

  • Approve CSR Policy,
  • Disclose the policy in the BOD Report, and
  • Place the policy (with Committee composition & approved projects) on the company's website.

## 8. Activities NOT Treated as CSR

  • Activities undertaken in normal course of business.
  • Activities benefiting employees of the company.
  • Activities undertaken outside India — except training of Indian sports personnel representing State/UT (national level) or India (international level).
  • Activities done on a sponsorship basis to derive marketing benefit for products/services.
  • Contribution to a political party, direct or indirect.
  • Activities fulfilling other statutory obligations.

## 9. Schedule VII — Permitted CSR Areas (Indicative)

Promoting gender equality, sports, employment, health, education; Har Ghar Tiranga Campaign; eradicating hunger & poverty; contribution to universities, Swach Bharat Kosh, PM National Relief Fund, PM CARES Fund or funds set up by CG; slum area development; rural development; disaster management; benefit of armed forces veterans; etc.

Worked example

### Example 1

Example — Younger company: S Ltd. was incorporated on 30.04.2024. Net profit before tax: FY 2024-25 = ₹5 crore; FY 2025-26 = ₹7 crore. As the company has not completed 3 FYs, the CSR spend for FY 2026-27 = 2% of the average of these 2 years = 2% × ₹6 crore = ₹12 lakhs.

### Example 2

Example — Excess set-off: R Ltd.'s CSR obligation for FY 2025-26 = ₹50 lakhs, but it spends ₹60 lakhs. The ₹10 lakh excess can be set off against the CSR obligation in any of the next 3 FYs (2026-27 to 2028-29), only if BOD passes a resolution. Surplus generated by CSR project does not count as excess.

### Example 3

Example — Ongoing vs Non-ongoing: Z Ltd. has unspent ₹40 lakhs at FY-end 31.03.2026. (i) If pertaining to an ongoing project, must be transferred to Unspent CSR A/c by 30.04.2026 and spent within 3 FYs. (ii) If pertaining to a one-time project, must be transferred to a Schedule VII Fund by 30.09.2026.

### Example 4

Example — Penalty: Z Ltd. fails to transfer ₹40 lakhs unspent CSR to a Schedule VII Fund. Penalty on company = lower of (2 × ₹40 lakhs = ₹80 lakhs) or ₹1 crore = ₹80 lakhs. Penalty on officer in default = lower of (1/10 × ₹40 lakhs = ₹4 lakhs) or ₹2 lakhs = ₹2 lakhs.

⚠️ Common exam mistakes

  • Computing CSR on profit after tax — Section 135 uses net profit u/s 198 (before tax adjustments per Sec 198), excluding overseas-branch profit and dividend from an Indian CSR-company.
  • Counting surplus from CSR activities as eligible for set-off — only excess spend can be set off; surplus must be re-deployed or transferred.
  • Confusing the 30-day timeline (ongoing project — to Unspent CSR A/c) with the 6-month timeline (non-ongoing — directly to Schedule VII Fund).
  • Ignoring that even companies with CSR obligation ≤ ₹50 lakhs that hold an Unspent CSR A/c MUST still constitute a CSR Committee.
  • Treating activities benefiting employees, political contributions, or those done in the normal course of business as CSR — they are excluded.
  • Treating activities outside India as CSR — they are excluded, except training of Indian sports personnel for national/international representation.
  • Counting direct project implementation costs as 'admin overhead' under the 5% cap — they are not.
Bare-Act text Section 135 · Companies Act, 2013 · click to expand
Section 135 — Corporate Social Responsibility: Every company having (a) net worth of ₹500 crores or more, or (b) turnover of ₹1,000 crores or more, or (c) net profit of ₹5 crores or more, during the immediately preceding financial year, shall constitute a CSR Committee of the Board consisting of three or more directors, out of which at least one director shall be an independent director. The Board of every such company shall ensure that the company spends, in every FY, at least 2% of the average net profits of the company made during the three immediately preceding FYs. Where the company has not completed three FYs since incorporation, average of such immediately preceding FYs shall be considered. Unspent amount pertaining to an ongoing project shall be transferred to Unspent CSR Account within 30 days of FY end and spent within 3 FYs; failing which, transferred to a Fund specified in Schedule VII within 30 days. Other unspent amount shall be transferred to Schedule VII Fund within 6 months of FY end. Default attracts penalty on the company (twice the unspent amount or ₹1 crore, whichever is less) and on officer in default (one-tenth of unspent amount or ₹2 lakhs, whichever is less).
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