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Microlesson · 5-min read

Corporate Social Responsibility – CSR Committee, Spending and Default (Section 135 & CSR Rules)

# Section 135 – Corporate Social Responsibility (CSR)

## 1. Applicability

Every company (including foreign company, holding, subsidiary) having in the immediately preceding financial year:

  • Net Worth ≥ ₹500 crore, OR
  • Turnover ≥ ₹1,000 crore, OR
  • Net Profit ≥ ₹5 crore

## 2. CSR Committee

The Board shall constitute a CSR Committee consisting of 3 or more directors, of which at least one shall be an Independent Director.

Exceptions:

SituationComposition
Company not required to have Independent DirectorCommittee with only directors (no ID needed)
Private Company with only 2 directorsCommittee can be of those 2 directors
Foreign CompanyAt least 2 persons – one is the authorised resident person under Sec 380(1)(d), other nominated by foreign company
CSR amount required ≤ ₹50 lakhCSR Committee not required; functions to be discharged by the Board

## 3. Functions of CSR Committee

1. Formulate and recommend a CSR Policy to the Board indicating activities (as per Schedule VII).

2. Recommend the CSR amount to be spent.

3. Monitor the CSR Policy from time to time.

## 4. CSR Expenditure

The Board shall ensure that the company spends, in every financial year, at least 2% of the average net profits of the company made during the 3 immediately preceding financial years (or such immediately preceding FYs if company is in existence for less than 3 years).

Preference: Local area and areas around which the company operates.

## 5. Treatment of Unspent CSR Amount

### Case A – Amount relates to an ongoing project

  • Transfer the unspent amount to a Special Account ('Unspent CSR Account') opened in a scheduled bank within 30 days from end of FY.
  • This unspent amount must be spent within 3 financial years from the date of transfer.
  • If still unspent after 3 FYs → transfer to a fund specified in Schedule VII within 30 days from end of 3rd FY.

### Case B – Amount NOT relating to ongoing project

  • Transfer the unspent amount to a fund specified in Schedule VII (e.g., PM National Relief Fund) within 6 months from end of FY.

### Reasons for Unspent Amount

The Board, in its report, shall specify the reasons for not spending the CSR amount.

## 6. Excess Spending – Set off

If the company spends an amount in excess of the required 2%, such excess can be set off against the CSR requirement of the next 3 financial years. (Such excess amount shall not include surplus arising from CSR activities.)

## 7. Penalty for Default in CSR Expenditure [Sec 135(7)]

PersonPenalty
CompanyTwice the unspent amount required to be transferred OR ₹1 crore, whichever is lower
Every Officer in DefaultOne-tenth of unspent amount OR ₹2 lakh, whichever is lower

## 8. CSR Rules – Activities

### Included

  • Activities undertaken by the company in pursuance of its CSR policy as per Schedule VII (education, healthcare, gender equality, rural development, etc.).

### Excluded (NOT counted as CSR)

1. Sponsorship expenses for marketing/derivation of marketing benefits.

2. Political contributions (direct or indirect).

3. Activities benefiting employees of the company.

4. Expense for fulfilling any statutory obligation under any other law.

5. Activities undertaken outside India.

  • Exception: Training of Indian sportspersons representing India at State / National / International level.

6. Activities undertaken in the ordinary course of business.

  • Exception: R&D activity in new vaccine / drugs / medical devices related to COVID-19 (FY 2020-21, 2021-22, 2022-23) by a company engaged in R&D, subject to conditions.

Worked example

### Example 1

Q. PQR Ltd's average net profit for the last 3 FYs is ₹100 crore. What is the CSR obligation?

A. CSR obligation = 2% × ₹100 crore = ₹2 crore. Since this exceeds ₹50 lakh, a CSR Committee with at least one Independent Director must be constituted.

### Example 2

Q. LMN Ltd has CSR obligation of ₹10 crore in FY 2024-25. It spent ₹6 crore and ₹4 crore relates to an ongoing project. How is ₹4 crore treated?

A. ₹4 crore must be transferred to an 'Unspent CSR Account' in a scheduled bank within 30 days of FY end (i.e., by 30 April 2025) and must be spent within 3 FYs. If not spent, transfer to Schedule VII fund within 30 days from end of 3rd FY.

### Example 3

Q. A company failed to spend ₹50 lakh of CSR (not relating to ongoing project) and did not transfer it. What is the penalty on the company?

A. Penalty = lower of (2 × ₹50 lakh = ₹1 crore) OR ₹1 crore = ₹1 crore.

⚠️ Common exam mistakes

  • Computing CSR on net profit of current year instead of average of preceding 3 years.
  • Forgetting that CSR Committee is NOT required if CSR amount ≤ ₹50 lakh – Board itself acts.
  • Confusing the time limit for transfer: 30 days for ongoing project (to Unspent Account); 6 months for non-ongoing project (to Schedule VII fund).
  • Treating employee welfare expenses or political donations as CSR – both are excluded.
  • Forgetting that the excess CSR amount set off applies for 3 succeeding FYs, not unlimited carry forward.
Bare-Act text Section 135 read with Companies (CSR Policy) Rules, 2014 · Companies Act, 2013 · click to expand
Section 135(1): 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 consisting of three or more directors, out of which at least one director shall be an independent director. Section 135(5): 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.
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