URBAN IMPROVEMENT TRUST (NOW KOTA DEVELOPMENT AUTHORITY),KOTA vs. DCIT (EXEMPTIONS), CIRCLE, JAIPUR, JAIPUR

ITA 811/JPR/2024Status: DisposedITAT Jaipur11 August 2025Bench: Dr. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)44 pages
AI SummaryDismissed

What did the Tribunal hold?

The ITAT held that the Urban Improvement Trust is an instrumentality of the State and falls under the purview of Article 289(1) of the Constitution of India. Consequently, its income is not chargeable under the Income Tax Act.

What were the facts?

The Income Tax Appellate Tribunal (ITAT) heard appeals concerning the taxability of income earned by the Urban Improvement Trust (UIT), Kota. The revenue contended that UIT's income was taxable, while UIT argued for its exemption.

What were the issues?

The primary issue was whether the income of the Urban Improvement Trust was exempt from income tax as income of a State under Article 289(1) of the Constitution, or if it was taxable under specific provisions of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 10(46),Section 10(46A)

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Income Tax Appellate Tribunal, JAIPUR BENCH “B”, JAIPUR

Before: Dr. S. SEETHALAKSHMI & SHRI GAGAN GOYAL

For Appellant: Mr. Prakul Khurana, Adv. &, Mr. Mukesh Soni, Adv. Adv., Ld. ARs
Hearing: 11/08/2025Pronounced: 11/08/2025

PER GAGAN GOYAL, A.M:

These appeals by assessee and revenue are directed against the order of NFAC, Delhi dated 22.03.2024

The order continues below.

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