DCIT(EXEMPTIONS)-1(1), MUMBAI, MUMBAI vs. BSE INVESTORS PROTECTION FUND, MUMBAI

ITA 8889/MUM/2025Status: DisposedITAT Mumbai13 August 2026AY 2017-1813 pages
AI SummaryDismissed

What were the facts?

The Revenue appealed against the CIT(A)'s order granting exemption to the BSE Investors Protection Fund. The primary dispute revolved around whether the trust's activities benefited specified persons under Section 13(3) and if the trust was irrevocable.

What did the Tribunal hold?

The Tribunal held that the trust's activities did not directly benefit the settlors or members, and the trust was indeed irrevocable as per its deed. The interest income on auction proceeds was also not taxable in the hands of the assessee.

What were the issues?

Whether the BSE Investors Protection Fund violated provisions related to benefiting specified persons and whether the trust was irrevocable, thus disentitling it from tax exemptions.

Which sections of the Income-tax Act were involved?

Section 10(23EA),Section 11,Section 12,Section 13(1)(c),Section 13(3),Section 11(7),Section 11(1)(d),Section 164(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI

Before: SHRI SANDEEP GOSAIN & SHRI JAGADISH

For Respondent: Shri Niraj Sheth
Pronounced: 13.08.2026

Heard together (6 matters)

ITA 7628/MUM/2025
ITA 7629/MUM/2025
ITA 7630/MUM/2025
ITA 8888/MUM/2025
ITA 8889/MUM/2025
ITA 8890/MUM/2025

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