TATA EDUCATION TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-CIRCLE 2(1), MUMBAI

ITA 4282/MUM/2024Status: DisposedITAT Mumbai10 October 2025AY 2014-15Bench: SHRI SAKTIJIT DEY (Vice President), SHRI NARENDRA KUMAR BILLAIYA (Accountant Member)42 pages
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What did the Tribunal hold?

The Tribunal held that a trust registered under Section 12A and eligible for Section 11 benefits can still claim exemptions under Sections 10(34) and 10(35). The Tribunal also allowed deductions under Sections 80G and 80GGA.

What were the facts?

The assessee, a charitable trust, claimed exemption on dividend and unit income. The AO denied this exemption, holding that investments violated Sections 13(1)(d) and 11(5) and that the trust was ineligible for Section 11 benefits.

What were the issues?

Whether a charitable trust eligible for Section 11 exemption can also claim exemptions under Sections 10(34) and 10(35)? Whether deductions under Sections 80G and 80GGA are allowable?

Which sections of the Income-tax Act were involved?

Section 10(34),Section 10(35),Section 11,Section 11(5),Section 13(1)(d),Section 13(2)(h),Section 80G,Section 80GGA

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IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT AND SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER ITA No.4282, 4283, /Mum/2024 (Assessment Years:2014-15, 2013-14,) Circle-2(1), Mumbai-400001 Mumbai (Appellant) : (Respondent) PAN NO. AAATT 9835A ITA No.4156, 4496, 4727 & 4835/Mum/2024 (Assessment Years:2015-16, 2016-17 & 2017-18) Tata Education Trust, Asst. Commissioner of Income Tax-17(3) Mumbai-400 051 Mumbai-400001 (Appellant) : (Respondent) PAN NO. AAATT 9835A ITA No.4852, 4419, 4873 /Mum/2024 (Assessment Years:2013-14, 2014-15 and 2017-18) Asst. Commissioner of Income Tax- Mumbai-400 051 Mumbai-400001 (Appellant) : (Respondent) PAN NO. AAATT 9835A

Appellant by : Shri P.J. Pardiwala a/w Shri Sukhsagar Syal & Shri Atul Suraiya Respondent by : Shri Ritesh Mishra, CIT DR (Appellant) (Respondent) Date of

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