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Income Tax Appellate Tribunal, DELHI BENCH ‘G’ : NEW DELHI
Before: SHRI O.P. KANT & SHRI KULDIP SINGH
per directions issued by the Board of Trustees to carry out various research projects as an Executive Director and being paid remuneration by the trustee stated to be commensurate to his
functional profile, there is no question of treating him as a
9 ITA No.7445/Del./2017
specified person under the garb of self created principle of “de facto trustee” merely on the ground that he is supervising the substantial activities of the trust. 14. In view of what has been discussed above, we are of the considered view that ld. CIT (A) has rightly reached the conclusion that provisions contained u/s 13(1)(cc)(ii) of the Act are not applicable to the case of the assessee trust. So, finding no illegality or perversity in the impugned order, appeal filed by the Revenue is dismissed. Order pronounced in open court on this 28th day of July, 2021.
Sd/- sd/- (O.P. KANT) (KULDIP SINGH) ACCOUNTANT MEMBER JUDICIAL MEMBER
Dated the 28th day of July, 2021 TS Copy forwarded to: 1.Appellant 2.Respondent 3.CIT 4.CIT(A)-40, Delhi. 5.CIT(ITAT), New Delhi. AR, ITAT NEW DELHI.