SANIDHYA ROONGTA BENEFIT TRUST,RAJEEV GANDHI NAGAR vs. ITO WARD 1(2), KOTA, INCOME TAX OOFICE KOTA

ITA 461/JPR/2025Status: DisposedITAT Jaipur06 August 2026AY 2015-169 pages
AI SummaryAllowed

What were the facts?

The assessee, a private specific trust, filed its income tax return in the wrong form (Form 7 instead of Form 5) for AY 2015-16 and 2016-17. This led to the denial of individual slab rate benefits and a demand for tax at the Maximum Marginal Rate (MMR). The assessee's rectification applications and appeals were rejected by the AO and CIT(A).

What did the Tribunal hold?

The Tribunal held that since the trust had a single, determined beneficiary, it should be taxed at individual slab rates, not MMR. The lower authorities erred in denying this benefit and rejecting the rectification.

What were the issues?

Whether a private specific trust with a single, determined beneficiary is liable to be taxed at the Maximum Marginal Rate or at individual slab rates.

Which sections of the Income-tax Act were involved?

Section 154,Section 160

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘SMC’ BENCH, JAIPUR

Before: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar

PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

These two appeals are filed by the assessee as against separate appellate orders both dated 20.08.2024 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (hereinafter referred to as “CIT(A)”), arising out of the rectification orders passed under section 154 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2015-16 and 2016-17. I.T.A Nos. 461 & 462/JPR/2025 Page No 2

2.

The registry has noted that there is delay of 145 days filing of above appeals. The assesse by way of notarized affidavit stated that the delay is due to fa

The order continues below.

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