Asstt. CIT v. Thanthi Trust

247 ITR 785Supreme Court of India2001#1157 most cited

What is Asstt. CIT v. Thanthi Trust authority for?

A charitable trust can earn income from business activities under Section 11(4A), including incidental businesses, and still claim exemption under Section 11, provided the income is applied towards its charitable objects. Generating a surplus from such activities does not automatically negate the charitable purpose.

98

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2026.

Also referred to as

Thanthi Trust · Asstt. CIT v. Thanthi Trust · Section 11 · Section 11(4A) · Section 2(15) · charitable trust business income · incidental business exemption · application of income · charitable purpose · surplus generation

Also reported as

115 Taxmann 126

Sections most often in play

Section 11Section 143(3)Section 2(15)Section 11(4A)Section 147Section 148Section 10(23C)Section 11(1)(a)

Issues it is cited on

section 4(3)section 11(4)section 35acsection 10(22)section 11(4a)section 205advancement of general public utilitysection 60section 115bbcsection 35asection 2(45)section 36(1)(v)

Judgments citing Asstt. CIT v. Thanthi Trust

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

ITA 1670/CHNY/2024[2018-19]Status: DisposedITAT Chennai21 Jan 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri G. Baskar, Advocate &For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

…me vide order dated 18.11.2024 in the case of Smt. Lingammal Ramaraju Shastra Prathistha Trust reported in 168 taxmann.com 476 (Chennai Tribunal). 31. Further he drew attention to the decision of Hon’ble Supreme Court in the case of Thanthi Trust reported in 247 ITR 785 (SC) and argued that the assessee can very well carry out any business activities under section 11(4A) of the Act only subject to the conditions mandated. He referred to page 151 of the paper book and submits that the Assessing Officer and 27 I.T.A. Nos.1667 to 1670/Chny/24 ld. CIT(A) both failed to consider the fact of assessee’s main object i.…

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

ITA 1667/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

…ame vide order dated 18.11.2024 in the case of Smt. Lingammal Ramaraju Shastra Prathistha Trust reported in 168 taxmann.com 476 (Chennai Tribunal). 31. Further he drew attention to the decision of Hon'ble Supreme Court in the case of Thanthi Trust reported in 247 ITR 785 (SC) and argued that the assessee can very well carry out any business activities under section 11(4A) of the Act only subject to the conditions mandated. He referred to page 151 of the paper book and submits that the Assessing Officer and Id. CIT(A) both failed to consider the fact of assessee's main object i.e. education, still actively in the…

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES ,MUMBAI vs. DCIT EXEMPTION-1(1), MUMBAI

In the result the appeal filed by the assessee stands allowed for statistical purposes

ITA 179/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Mar 2025AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarcredit Guarantee Fund Vs. Dcit(E) – 1(1) Trust Mumbai. 1St Floor, Sidbi Swavalaman Bhavan, Avenue – 3, Lane 2, G-Block, Bkc, Bandra (E) Pan/Gir No. Aaatc2613D (Applicant) (Respondent)

Section 11(1)(a)Section 11(1)(d)Section 12ASection 143(1)Section 2(24)Section 2(24)(iia)Section 250

…financing cannot by itself be a ground to say that the assessee does not exist for charitable purpose particularly when the MOA & AOA provide that the profit shall not be distributed amongst the members but shall be utilized towards the objects (Thanthi Trust 247 ITR 785 (SC) & Agricultural Produce and Market Committee 291 ITR 419 (Bom) followed) (b) Reference is also made to the decision dated 24th December, 2008 of ITAT, Bangalore Bench 'A' in the case of Asstt. Director of Income-tax (Exemption) vs. Bharatha Swamukhi Samsthe reported in (2009) 28 DTR (Bang) (Trib) 113. In this case, the assessee trust's work…

THE THANTHI TRUST,CHENNAI vs. CIT(EXEMPTIONS), CHENNAI

In the result, the appeal of the assessee is allowed

ITA 1369/CHNY/2024[2018-19]Status: DisposedITAT Chennai26 Nov 2024AY 2018-19

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1369/Chny/2024 िनधा"रणवष" / Assessment Year: 2018-19 Commissioner Of Income Tax The Thanthi Trust, V. (Exemptions), No. 86, Evk Sampath Road, Chennai – 600 034. Vepery, Chennai – 600 007. [Pan: Aaatt-0038-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. V.S. Jayakumar, Sr. Advocate For Shri.Mudit Bohara, Advocate & Shri. K.R. Adivarahan, Ca ""यथ"क"ओरसे/Respondent By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 30.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 26.11.2024 आदेश /O R D E R

For Appellant: Shri. V.S. Jayakumar, Sr. Advocate for Shri.Mudit Bohara, Advocate and Shri. K.RFor Respondent: Shri. Nilay Baran Som, CIT
Section 11(4)Section 12ASection 143(1)Section 143(2)Section 143(3)Section 263

…009-10 to 2012-13(ITA Nos.1532,1533 &1534/CHNY/2015 & 2720/CHNY/2017), the decision of Madras High Court in the Appellants own case reported in T.C.A No.822 of 2018, order dated 29.10.2020 and the Supreme Court decision in the Appellant's own case reported in 247 ITR 785 (2001). 5. The Commissioner of Income Tax (Exemptions) had erred in not considering the fact that the business was held under trust as per provisions of section 11(4) of Income Tax Act 1961 as decided by the Madras High Court in the Appellant's own case reported in T.C.A No.822 of 2018, order dated 29.10.2020. 6. For these and other grounds that…

SREE NARAYANA DHARMA SABHA,KODUNGALLUR-THRISSUR vs. INCOME TAX OFFICER(EXEMPTION), THRISSUR

In the result, the appeals filed by the assessee are allowed

ITA 154/COCH/2024[2018-19]Status: DisposedITAT Cochin08 Nov 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

…herein the department had accepted the claim of the assessee. The learned AR also relied on the judgment of the Delhi High Court reported in 447 ITR 99 in the case of PCIT v. Servants of People Society and the judgment of the Hon’ble Supreme Court reported in 247 ITR 785 in the case of ACIT v. Thanthi Trust, in support of his arguments that the income earned through kuri and finance business should not be treated as business income when the entire income was spent on the charitable activities. The learned AR also relied on the order of the Bangalore Tribunal reported in 2023 (9 TMI 256) in the case of Navodaya Gr…

SREE NARAYANA DHARMA SABHA,KODUNGALLUR-THRISSUR vs. INCOME TAX OFFICER(EXEMPTION), THRISSUR

In the result, the appeals filed by the assessee are allowed

ITA 153/COCH/2024[2016-17]Status: DisposedITAT Cochin08 Nov 2024AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

…herein the department had accepted the claim of the assessee. The learned AR also relied on the judgment of the Delhi High Court reported in 447 ITR 99 in the case of PCIT v. Servants of People Society and the judgment of the Hon’ble Supreme Court reported in 247 ITR 785 in the case of ACIT v. Thanthi Trust, in support of his arguments that the income earned through kuri and finance business should not be treated as business income when the entire income was spent on the charitable activities. The learned AR also relied on the order of the Bangalore Tribunal reported in 2023 (9 TMI 256) in the case of Navodaya Gr…

SREE NARAYANA DHARMA SABHA,KODUNGALLUR-THRISSUR vs. INCOME TAX OFFICER(EXEMPTION), THRISSUR

In the result, the appeals filed by the assessee are allowed

ITA 152/COCH/2024[2015-16]Status: DisposedITAT Cochin08 Nov 2024AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

…herein the department had accepted the claim of the assessee. The learned AR also relied on the judgment of the Delhi High Court reported in 447 ITR 99 in the case of PCIT v. Servants of People Society and the judgment of the Hon’ble Supreme Court reported in 247 ITR 785 in the case of ACIT v. Thanthi Trust, in support of his arguments that the income earned through kuri and finance business should not be treated as business income when the entire income was spent on the charitable activities. The learned AR also relied on the order of the Bangalore Tribunal reported in 2023 (9 TMI 256) in the case of Navodaya Gr…

SREE NARAYANA DHARMA SABHA,KODUNGALLUR-THRISSUR vs. INCOME TAX OFFICER(EXEMPTION), THRISSUR

In the result, the appeals filed by the assessee are allowed

ITA 151/COCH/2024[2013-14]Status: DisposedITAT Cochin08 Nov 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

…herein the department had accepted the claim of the assessee. The learned AR also relied on the judgment of the Delhi High Court reported in 447 ITR 99 in the case of PCIT v. Servants of People Society and the judgment of the Hon’ble Supreme Court reported in 247 ITR 785 in the case of ACIT v. Thanthi Trust, in support of his arguments that the income earned through kuri and finance business should not be treated as business income when the entire income was spent on the charitable activities. The learned AR also relied on the order of the Bangalore Tribunal reported in 2023 (9 TMI 256) in the case of Navodaya Gr…

SREE NARAYANA DHARMA SABHA,KODUNGALLUR-THRISSUR vs. INCOME TAX OFFICER(EXEMPTION), THRISSUR

In the result, the appeals filed by the assessee are allowed

ITA 150/COCH/2024[2012-13]Status: DisposedITAT Cochin08 Nov 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Sri.P.J.Anil Kumar, AdvocaateFor Respondent: Smt.Girly Albert, Sr.DR
Section 11Section 143(1)Section 2(15)

…herein the department had accepted the claim of the assessee. The learned AR also relied on the judgment of the Delhi High Court reported in 447 ITR 99 in the case of PCIT v. Servants of People Society and the judgment of the Hon’ble Supreme Court reported in 247 ITR 785 in the case of ACIT v. Thanthi Trust, in support of his arguments that the income earned through kuri and finance business should not be treated as business income when the entire income was spent on the charitable activities. The learned AR also relied on the order of the Bangalore Tribunal reported in 2023 (9 TMI 256) in the case of Navodaya Gr…

M/S INNOVTIVE MICROFINANCE FOR POVERTY ALLEVIATION,CHENNAI vs. DCIT(EXEMPTIONS),CHENNAI CIRCLE, CHENNAI

In the result, the appeal filed by the assessee is dismissed

ITA 164/CHNY/2024[2013-14]Status: DisposedITAT Chennai10 Jul 2024AY 2013-14

Bench: Shri Mahavir Singhand Shri Jagadish

For Appellant: Shri M.V. Swaroop, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 11Section 12ASection 13(8)Section 143(3)Section 2(15)

…should be complied with; firstly, the rate should be comparable with the market and secondly, it should not be such that it generates profit at the cost of the beneficiaries. "'] The appellant has cited the Supreme Court ruling in CIT v. Thanthi Trust [2001] 247 ITR 785. In this case the Hon'ble Apex Court held that income from incidental business was permissible if the amount was applied for charitable purposes. The appellant has totally misunderstood the ruling and nowhere it suggests that the primary charitable activity can be run for profit on commercial principles. The ruling was specifically confined to su…

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

ITA 745/BANG/2023[2018-19]Status: DisposedITAT Bangalore03 Jan 2024AY 2018-19

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

Section 11Section 2(15)Section 234ASection 8

…should be complied with; firstly, the rate should be comparable with the market and secondly, it should not be such that it generates profit at the cost of the beneficiaries. "'] The appellant has cited the Supreme Court ruling in CIT v. Thanthi Trust [2001J 247 ITR 785. In this case the Hon'ble Apex Court held that income from incidental business was permissible if the amount was applied for charitable purposes. The appellant has totally misunderstood the ruling and nowhere it suggests that the primary charitable activity can be run for profit on commercial principles. The ruling was specifically confined to su…

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

ITA 744/BANG/2023[2016-17]Status: DisposedITAT Bangalore03 Jan 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

For Appellant: Shri Ravishankar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 11Section 2(15)Section 234ASection 8

…should be complied with; firstly, the rate should be comparable with the market and secondly, it should not be such that it generates profit at the cost of the beneficiaries. "'] The appellant has cited the Supreme Court ruling in CIT v. Thanthi Trust [2001J 247 ITR 785. In this case the Hon'ble Apex Court held that income from incidental business was permissible if the amount was applied for charitable purposes. The appellant has totally misunderstood the ruling and nowhere it suggests that the primary charitable activity can be run for profit on commercial principles. The ruling was specifically confined to su…

BIOWIN AGRO RESEARCH,MANANTHAWADY vs. INCOME TAX OFFICER, KOZHIKODE

In the result, the assessee’s appeals are dismissed

ITA 3/COCH/2022[2018-2019]Status: DisposedITAT Cochin24 Feb 2023AY 2018-2019

Bench: Shri Sanjay Arora, Hon’Ble & Shri Sandeep Gosain, Hon'Ble

For Appellant: Ms. Krishna. K, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 11Section 12ASection 143(3)Section 2(15)Section 25Section 8

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN BEFORE SHRI SANJAY ARORA, HON’BLE ACCOUNTANT MEMBER & SHRI SANDEEP GOSAIN, HON'BLE JUDICIAL MEMBER I.T.A. No. 02 & 03/COCH/2022 (Asst. Years: 2017-18 & 2018-19) Biowin Agro Research, vs. ITO, Exemption Ward, MP 5/587 D, Vemom, Kozhikode Mananthawady, Wayanad. [PAN: AAFCB 6169 B] (Appellant) (Respondent) Appellant by : Ms. Krishna. K, Advocate Respondent by : Smt. J.M. Jamuna Devi, Sr. DR Date of hearing : 02/02/2023 Date of pronouncement : 24/02/2023 O R D E R Per Bench: This is a set of two Appeals by the Assessee directed against the Order by the Nati…

BIOWIN AGRO RESEARCH,MANANTHAWADY vs. INCOME TAX OFFICER, KOZHIKODE

In the result, the assessee’s appeals are dismissed

ITA 2/COCH/2022[2017-2018]Status: DisposedITAT Cochin24 Feb 2023AY 2017-2018

Bench: Shri Sanjay Arora, Hon’Ble & Shri Sandeep Gosain, Hon'Ble

For Appellant: Ms. Krishna. K, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 11Section 12ASection 143(3)Section 2(15)Section 25Section 8

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN BEFORE SHRI SANJAY ARORA, HON’BLE ACCOUNTANT MEMBER & SHRI SANDEEP GOSAIN, HON'BLE JUDICIAL MEMBER I.T.A. No. 02 & 03/COCH/2022 (Asst. Years: 2017-18 & 2018-19) Biowin Agro Research, vs. ITO, Exemption Ward, MP 5/587 D, Vemom, Kozhikode Mananthawady, Wayanad. [PAN: AAFCB 6169 B] (Appellant) (Respondent) Appellant by : Ms. Krishna. K, Advocate Respondent by : Smt. J.M. Jamuna Devi, Sr. DR Date of hearing : 02/02/2023 Date of pronouncement : 24/02/2023 O R D E R Per Bench: This is a set of two Appeals by the Assessee directed against the Order by the Nati…

POPULATION SERVICES INTERNATIONAL,NEW DELHI vs. CIT(E), NEW DELHI

In the result, the appeal is allowed

ITA 433/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Nov 2022AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2016-17

Section 10Section 11Section 12ASection 2(15)Section 44ASection 80G

…for determining whether a particular activity is for charitable purpose or commercial nature. In this context, he drew our attention to the following decisions: 1. Addl. CIT Vs. Surat Art Silk Cloth Manufacturers, 121 ITR 1 (SC) 2. ACIT Vs. Thanti Trust, 247 ITR 785 (SC) 3. India Trade Promotion Organization Vs. DIT (E), 371 ITR 333 (Del) 15. Proceeding further, he submitted, the assessee was earlier granted approval under section 10(23C)(iv) of the Act for the assessment year 2007-08 and it was renewed year after year till its withdrawal by the impugned order. He submitted, when the objects of the asse…

THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), BANGALORE vs. M/S SRI BASAVESHWAR VEERASHAIVA VIDYAVARDHAK SANGHA , BAGALKOTE

In the result, the assessee’s appeals in ITA Nos

ITA 66/BANG/2018[2014-15]Status: DisposedITAT Bangalore29 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ed from the property held under the trust. We find that the apex Court in the case of Asstt. CIT vs. Thanthi Trust (2001) 165 ITA Nos.2775, 2776 & 2777/Bang/2017 ITA Nos.64, 65 & 66/Bang/2018 & ITA Nos.235 & 236/Bang/2018 Page 23 of 68 CTR (SC) 681 : (2001) 247 ITR 785 (SC) considered the provisions of s. 11(4A). His Lordship Hon'ble Mr. Justice S.P. Bharucha (as His Lordship then was) speaking for the Bench of the apex Court has observed as follows : "The substituted sub-s. (4A) states that the income derived from a business held under trust wholly for charitable or religious purposes shall not be included in…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), BANGALORE vs. M/S SRI BASAVESHWAR VEERASHAIVA VIDYAVARDHAK SANGHA , BAGALKOTE

In the result, the assessee’s appeals in ITA Nos

ITA 65/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ed from the property held under the trust. We find that the apex Court in the case of Asstt. CIT vs. Thanthi Trust (2001) 165 ITA Nos.2775, 2776 & 2777/Bang/2017 ITA Nos.64, 65 & 66/Bang/2018 & ITA Nos.235 & 236/Bang/2018 Page 23 of 68 CTR (SC) 681 : (2001) 247 ITR 785 (SC) considered the provisions of s. 11(4A). His Lordship Hon'ble Mr. Justice S.P. Bharucha (as His Lordship then was) speaking for the Bench of the apex Court has observed as follows : "The substituted sub-s. (4A) states that the income derived from a business held under trust wholly for charitable or religious purposes shall not be included in…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), BANGALORE vs. M/S SRI BASAVESHWAR VEERASHAIVA VIDYAVARDHAK SANGHA , BAGALKOTE

In the result, the assessee’s appeals in ITA Nos

ITA 64/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Aug 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ed from the property held under the trust. We find that the apex Court in the case of Asstt. CIT vs. Thanthi Trust (2001) 165 ITA Nos.2775, 2776 & 2777/Bang/2017 ITA Nos.64, 65 & 66/Bang/2018 & ITA Nos.235 & 236/Bang/2018 Page 23 of 68 CTR (SC) 681 : (2001) 247 ITR 785 (SC) considered the provisions of s. 11(4A). His Lordship Hon'ble Mr. Justice S.P. Bharucha (as His Lordship then was) speaking for the Bench of the apex Court has observed as follows : "The substituted sub-s. (4A) states that the income derived from a business held under trust wholly for charitable or religious purposes shall not be included in…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), BANGALORE vs. SRI V C CHARANTIMATH , BAGALKOT

In the result, the assessee’s appeals in ITA Nos

ITA 236/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ed from the property held under the trust. We find that the apex Court in the case of Asstt. CIT vs. Thanthi Trust (2001) 165 ITA Nos.2775, 2776 & 2777/Bang/2017 ITA Nos.64, 65 & 66/Bang/2018 & ITA Nos.235 & 236/Bang/2018 Page 23 of 68 CTR (SC) 681 : (2001) 247 ITR 785 (SC) considered the provisions of s. 11(4A). His Lordship Hon'ble Mr. Justice S.P. Bharucha (as His Lordship then was) speaking for the Bench of the apex Court has observed as follows : "The substituted sub-s. (4A) states that the income derived from a business held under trust wholly for charitable or religious purposes shall not be included in…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), BANGALORE vs. SRI.V.C.CHARANTIMATH , BAGALKOT

In the result, the assessee’s appeals in ITA Nos

ITA 235/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Aug 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ed from the property held under the trust. We find that the apex Court in the case of Asstt. CIT vs. Thanthi Trust (2001) 165 ITA Nos.2775, 2776 & 2777/Bang/2017 ITA Nos.64, 65 & 66/Bang/2018 & ITA Nos.235 & 236/Bang/2018 Page 23 of 68 CTR (SC) 681 : (2001) 247 ITR 785 (SC) considered the provisions of s. 11(4A). His Lordship Hon'ble Mr. Justice S.P. Bharucha (as His Lordship then was) speaking for the Bench of the apex Court has observed as follows : "The substituted sub-s. (4A) states that the income derived from a business held under trust wholly for charitable or religious purposes shall not be included in…

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