In the given question we can understand the situation in the both cases
Case 1 :-
Whether the court reduced the fine of $25 millions for starting of foundation or any other reason
Case 2:-
whether the court deducted the $25 millions from fine for the reason of starting a foundation
In case 1 the 25 millions are treated as benefits given to the company
But, in the case 2 25 millions are treated as deduction in the fine amount
If court gave benefit to the company , then the company can deduct that 25 millions from the income and pay income tax for rest of income
If the court treats that 25 millions as deduction of fine then it will be a part of income and tax should be paid on collective income including this 25 millions
So, now we want to prove that the court has given the benefit to company because the company voluntarily started foundation for the employees
So, voluntary starting of foundation will leads to benefits to employees and that benefits is from company in nature of charity and welfare of the employees.
So the company can eliminate the 25 millions from income and pay income tax on rest of this 25 millions.
As per above explanation the company intention for starting foundation is safety and welfare of employees in charity nature so the total expenses incurred to the foundation can be get deduction and pay tax on rest of 25 millions.
I hope, all the given information is useful to you.
Thank you.
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