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Microlesson · 5-min read

Corporate Social Responsibility — Applicability and Spending Obligation (Section 135)

# Corporate Social Responsibility (CSR) — Section 135

## Concept of CSR

CSR implies that companies voluntarily integrate social and environmental concerns into their business operations for the betterment of stakeholders and society. Section 135 makes mandatory spending on CSR a statutory obligation for certain companies.

## Applicability — Who Must Constitute a CSR Committee?

Every company — including its holding or subsidiary, and a foreign company [Section 2(42)] having its branch office or project office in India — falls within CSR scope if, during the immediately preceding financial year, it meets ANY ONE of the following:

CriterionThreshold
Net Worth≥ ₹500 Crores
Turnover≥ ₹1,000 Crores
Net Profit≥ ₹5 Crores

> The triggers are alternative (any one suffices), not cumulative.

Any company meeting the criteria must constitute a CSR Committee of the Board.

## Definitions

### Net Worth — Section 2(57)

Net Worth = (Paid-up Share Capital + All Reserves created out of Profits + Securities Premium A/c) − (Accumulated Losses + Deferred Expenditure + Misc. Expenditure not written off)

As per the audited Balance Sheet, but does NOT include:

  • Reserves created out of revaluation of assets
  • Write-back of depreciation
  • Reserves arising on amalgamation

### Net Profit (for CSR Purposes)

  • Average net profit is calculated per Section 198.
  • Net profit shall NOT include:
  • (a) Profit from any overseas branch(es) of the company, whether operated as a separate company or not.
  • (b) Any dividend received from other Indian companies that are themselves covered under and complying with Section 135.
  • Net profits for any FY for which FS were prepared under the Companies Act, 1956, need NOT be re-calculated under the 2013 Act.
  • For a foreign company: Net profit = Net profit as per P&L prepared under Section 381 read with Section 198.

## Amount of CSR Contribution

The Board of Directors of every company falling within Section 135 shall ensure that the company spends, in every FY:

> At least 2% of Average Net Profits of the immediately preceding 3 Financial Years.

While spending, the company shall give preference to local areas around where it operates.

## Failure to Spend — Two Scenarios

### Scenario A — Company has NO ongoing CSR Project

  • Board shall disclose the reason for not spending in its Board's Report; AND
  • The unspent amount shall be transferred to a Fund specified in Schedule VII (e.g., PM National Relief Fund) within 6 months from the end of the FY.

### Scenario B — Company HAS Ongoing CSR Projects

  • Unspent amount shall be transferred to a special account named "Unspent CSR Account" maintained with a scheduled bank.
  • Transfer must happen within 30 days from the end of the FY.
  • Such amount must be spent within 3 FYs from the date of transfer, in pursuance of the CSR obligation.
  • If the company fails to spend within those 3 FYs, the amount shall be transferred to a Fund specified in Schedule VII within 30 days from the end of the 3rd FY.

## Memory Snapshot — Timelines

SituationActionTimeline
No ongoing project — unspentTransfer to Schedule VII Fund6 months from end of FY
Ongoing project — unspentTransfer to Unspent CSR A/c (scheduled bank)30 days from end of FY
Ongoing project — still unspent after 3 FYsTransfer to Schedule VII Fund30 days from end of 3rd FY

Worked example

### Example 1

Example 1 (Applicability): Alpha Ltd has: Net Worth ₹300 Cr, Turnover ₹1,200 Cr, Net Profit ₹4 Cr in FY 2024-25. Since Turnover ≥ ₹1,000 Cr (one criterion met), CSR is APPLICABLE for FY 2025-26.

### Example 2

Example 2 (Average Net Profit): Beta Ltd had net profits of ₹8 Cr, ₹10 Cr, ₹12 Cr in the 3 immediately preceding FYs. Average = ₹10 Cr. CSR spending obligation = 2% × ₹10 Cr = ₹20 lakhs.

### Example 3

Example 3 (Failure to spend — no ongoing project): Gamma Ltd was required to spend ₹50 lakhs in FY 2024-25 but spent only ₹30 lakhs. The unspent ₹20 lakhs (no ongoing project) must be transferred to a Schedule VII Fund by 30th September 2025 (within 6 months from 31 March 2025), and reasons must be disclosed in Board's Report.

### Example 4

Example 4 (Ongoing Project): Delta Ltd was required to spend ₹1 Cr in FY 2024-25; it spent ₹70 lakhs on an ongoing 2-year project but ₹30 lakhs remained unspent. It must transfer ₹30 lakhs to 'Unspent CSR Account' with a scheduled bank by 30 April 2025 (30 days from end of FY). It must spend that ₹30 lakhs by 31 March 2028 (within 3 FYs), failing which it transfers to a Schedule VII Fund by 30 April 2028.

### Example 5

Example 5 (Foreign Co): Zen Inc., a foreign company with a project office in India, has its Indian operations net profit at ₹6 Cr (per Section 381 read with 198). CSR applies — committee must be constituted.

⚠️ Common exam mistakes

  • Treating CSR thresholds as cumulative — they are ALTERNATIVE; meeting any ONE of Net Worth ≥ ₹500 Cr, Turnover ≥ ₹1,000 Cr, or Net Profit ≥ ₹5 Cr triggers Section 135.
  • Computing 2% on the CURRENT year's profits — it must be the AVERAGE net profit of the 3 IMMEDIATELY PRECEDING FYs.
  • Forgetting to EXCLUDE overseas branch profits and dividends from Section 135-compliant companies while computing net profit for CSR.
  • Confusing the two timelines for unspent amount transfer: 6 months (no ongoing project → Schedule VII Fund) vs. 30 days (ongoing project → Unspent CSR A/c).
  • Believing CSR doesn't apply to foreign companies — it applies to foreign companies (per Sec 2(42)) having a branch / project office in India, if thresholds are met.
  • Including revaluation reserves or amalgamation reserves while computing Net Worth — these are specifically excluded under Section 2(57).
  • Treating spending preference for 'local areas' as mandatory — it is a preference, not a strict mandate.
Bare-Act text Section 135 and Section 2(57) · Companies Act, 2013 read with Companies (CSR Policy) Rules, 2014 · click to expand
Every company having net worth of rupees five hundred crore or more, or turnover of rupees one thousand crore or more or a net profit of rupees five crore or more during the immediately preceding financial year shall constitute a Corporate Social Responsibility Committee of the Board... The Board of every company referred to in sub-section (1) shall ensure that the company spends, in every financial year, at least two per cent of the average net profits of the company made during the three immediately preceding financial years... If the company fails to spend such amount, the Board shall, in its report... specify the reasons for not spending the amount and, unless the unspent amount relates to any ongoing project... transfer such unspent amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.
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