CIT v. Audyogik Shikshan Mandal

261 Taxmann 12High Court2019#6028 most cited

What is CIT v. Audyogik Shikshan Mandal authority for?

Where a trust violates provisions of Section 13(1)(d), the exemption under Section 11 is forfeited only on the income used for non-charitable purposes, not the entire income of the trust. The legislature did not intend to deny the benefit of Section 11 to the entire income of the trust in such cases.

19

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2019 to 2022.

Also referred to as

CIT v. Audyogik Shikshan Mandal · Section 11 · Section 13(1)(d) · forfeiture of exemption · entire income · prohibited application of income · maximum marginal rate

Issues it is cited on

section 13(l)(d)section 2(29c)section 243section 164(2)section 13(1)(d)section 209section 208section 164section 13(2)section 244interest under section 234cmaximum marginal rate

Judgments citing CIT v. Audyogik Shikshan Mandal

R.D.Tata Trust, Mumbai vs. ITO (E)-2(2) (Now Assessed by the Asstt.CIT 17(3)), Mumbai

Accordingly, Ground No.3 to 5 raised by the Revenue are dismissed

ITA 3081/MUM/2018[2012-13]Status: DisposedITAT Mumbai17 Jun 2022AY 2012-13
For Appellant: Shri Sukhsagar SyalFor Respondent: Shri S N Kabra
Section 10(34)Section 11Section 12ASection 13(1)(d)Section 143(2)Section 143(3)Section 234A

…IN THE INCOME TAX APPELLATE TRIBUNAL "F" BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER R D Tata Trust, Ground Floor, Bombay House, Homi Mody Street, Fort, Mumbai - 400001 [PAN: AAATR8173R] ……………… Appellant Vs Asst. Commissioner of Income Tax, 17(3), Mumbai, [Earlier assessed by the Income Tax Officer (Exemptions)-2(2)], 1st Floor, Aayakar Bhavan, Maharshi Karve Road, Mumbai - 400020 ……………… Respondent Income Tax Officer (Exemption) - (2)(2), Mumbai Room No. 502, 5th Floor, Piramal Chambers, Lalbaug, Lower Parel, Mumbai - 400077 ……………… Appellant Vs R D Tata Trust, Gro…

ACIT- 17 (3), Mumbai vs. Tata Education Trust, Mumbai

In the result, both the appeals of the assessee’s and revenue

ITA 3153/MUM/2018[2012-13]Status: DisposedITAT Mumbai14 Jun 2022AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No. 3079/Mum/2018 (निर्धारण वर्ा / Assessment Year:2012-13) Tata Social Welfare Trust बिधम/ Ito (Exemption)-2(4) Bombay House, (Now Assessed By The Acit- Vs. 24, Homi Mody Street, 17(3), Mumbai), Piramal Fort, Mumbai-400001. Chambers, Lalbaug, Parel, Mumbai-400012. Pan No: Aaatt9834B

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Rajesh Damor (dR)
Section 10(34)Section 11Section 13Section 13(1)(d)

…ata Social Welfare Trust & Tata Education Trust which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

ACIT- 17 (3), Mumbai vs. Tata Social Welfare Trust, Mumbai

In the result, both the appeals of the assessee’s and revenue

ITA 3152/MUM/2018[2012-13]Status: DisposedITAT Mumbai14 Jun 2022AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No. 3079/Mum/2018 (निर्धारण वर्ा / Assessment Year:2012-13) Tata Social Welfare Trust बिधम/ Ito (Exemption)-2(4) Bombay House, (Now Assessed By The Acit- Vs. 24, Homi Mody Street, 17(3), Mumbai), Piramal Fort, Mumbai-400001. Chambers, Lalbaug, Parel, Mumbai-400012. Pan No: Aaatt9834B

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Rajesh Damor (dR)
Section 10(34)Section 11Section 13Section 13(1)(d)

…ata Social Welfare Trust & Tata Education Trust which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Tata Education Trust, Mumbai vs. ITO (E)-2(4) (No Assessed by the ACIT 17(3), Mumbai

In the result, both the appeals of the assessee’s and revenue

ITA 3080/MUM/2018[2012-13]Status: DisposedITAT Mumbai14 Jun 2022AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No. 3079/Mum/2018 (निर्धारण वर्ा / Assessment Year:2012-13) Tata Social Welfare Trust बिधम/ Ito (Exemption)-2(4) Bombay House, (Now Assessed By The Acit- Vs. 24, Homi Mody Street, 17(3), Mumbai), Piramal Fort, Mumbai-400001. Chambers, Lalbaug, Parel, Mumbai-400012. Pan No: Aaatt9834B

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Rajesh Damor (dR)
Section 10(34)Section 11Section 13Section 13(1)(d)

…ata Social Welfare Trust & Tata Education Trust which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Tata Social Welfare Trust, Mumbai vs. ITO(E)-2(4) (Now Assessed by the ACIT-17(3) ), Mumbai

In the result, both the appeals of the assessee’s and revenue

ITA 3079/MUM/2018[2012-13]Status: DisposedITAT Mumbai14 Jun 2022AY 2012-13

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No. 3079/Mum/2018 (निर्धारण वर्ा / Assessment Year:2012-13) Tata Social Welfare Trust बिधम/ Ito (Exemption)-2(4) Bombay House, (Now Assessed By The Acit- Vs. 24, Homi Mody Street, 17(3), Mumbai), Piramal Fort, Mumbai-400001. Chambers, Lalbaug, Parel, Mumbai-400012. Pan No: Aaatt9834B

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Rajesh Damor (dR)
Section 10(34)Section 11Section 13Section 13(1)(d)

…ata Social Welfare Trust & Tata Education Trust which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Assistant Commissioner of Income Tax 17(2)), Mumbai vs. Navjbai Ratan Tata Trust, Mumbai

In the result, appeal by the Revenue being ITA No

ITA 2162/MUM/2018[2014-15]Status: DisposedITAT Mumbai10 Mar 2022AY 2014-15

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

Section 11Section 13(1)(d)Section 164(2)Section 2Section 250

…nal rate of tax only to that part of the income which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Assistant Commissioner of Income Tax 17(2)), Mumbai vs. Navjbai Ratan Tata Trust, Mumbai

In the result, appeal by the Revenue being ITA No

ITA 2161/MUM/2018[2013-14]Status: DisposedITAT Mumbai10 Mar 2022AY 2013-14

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

Section 11Section 13(1)(d)Section 164(2)Section 2Section 250

…nal rate of tax only to that part of the income which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Navjbai Ratan Tata Trust, Mumbai vs. Assistant Commissioner of Income Tax 17(2)), Mumbai

In the result, appeal by the Revenue being ITA No

ITA 2116/MUM/2018[2014-15]Status: DisposedITAT Mumbai10 Mar 2022AY 2014-15

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

Section 11Section 13(1)(d)Section 164(2)Section 2Section 250

…nal rate of tax only to that part of the income which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Navjbai Ratan Tata Trust, Mumbai vs. Assistant Commissioner of Income Tax 17(2)), Mumbai

In the result, appeal by the Revenue being ITA No

ITA 2115/MUM/2018[2013-14]Status: DisposedITAT Mumbai10 Mar 2022AY 2013-14

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

Section 11Section 13(1)(d)Section 164(2)Section 2Section 250

…nal rate of tax only to that part of the income which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Assistant Commissioner of Income Tax 17(2)), Mumbai vs. Navjbai Ratan Tata Trust, Mumbai

In the result, appeal by the Revenue being ITA No

ITA 1316/MUM/2018[2011-12]Status: DisposedITAT Mumbai10 Mar 2022AY 2011-12

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

Section 11Section 13(1)(d)Section 164(2)Section 2Section 250

…nal rate of tax only to that part of the income which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Assistant Commissioner of Income Tax 17(2)), Mumbai vs. Navjbai Ratan Tata Trust, Mumbai

In the result, appeal by the Revenue being ITA No

ITA 1314/MUM/2018[2012-13]Status: DisposedITAT Mumbai10 Mar 2022AY 2012-13

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

Section 11Section 13(1)(d)Section 164(2)Section 2Section 250

…nal rate of tax only to that part of the income which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Navjbai Ratan Tata Trust, Mumbai vs. Additional Director of Income Tax (Exemptions) Range-II(Now Assessed by the Assistant Commissioner of Income Tax 17(2)), Mumbai

In the result, appeal by the Revenue being ITA No

ITA 1302/MUM/2018[2012-13]Status: DisposedITAT Mumbai10 Mar 2022AY 2012-13

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

Section 11Section 13(1)(d)Section 164(2)Section 2Section 250

…nal rate of tax only to that part of the income which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

Navjbai Ratan Tata Trust, Mumbai vs. Additional Director of Income Tax (Exemptions) Range-II(Now Assessed by the Assistant Commissioner of Income Tax 17(2)), Mumbai

In the result, appeal by the Revenue being ITA No

ITA 1301/MUM/2018[2011-12]Status: DisposedITAT Mumbai10 Mar 2022AY 2011-12

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

Section 11Section 13(1)(d)Section 164(2)Section 2Section 250

…nal rate of tax only to that part of the income which has forfeited exemption. It does not refer to the entire income being subjected to maximum marginal rate of tax.” Further, Hon‟ble Jurisdictional High Court in the case of CIT v. Audyogik Shikshan Mandal: 261 Taxmann 12 held that on a plain reading of sections 11 and 13 of the Act, it is clear that the legislature did not contemplate the denial of benefit of section 11 of the Act to the entire income of the Trust. Following the decisions of Hon‟ble Jurisdictional High Court, similar view was also expressed by the Co-ordinate Bench of the Tribunal in assessee‟…

M/S Jaya Educational Trust, Thiruvallur vs. DCIT, CC1(2), Chennai

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

ITA 916/CHNY/2020[2017-18]Status: DisposedITAT Chennai16 Jul 2021AY 2017-18

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

For Appellant: Shri Y. Sridhar, CAFor Respondent: Shri S. Bharath, CIT
Section 11Section 12ASection 13(1)(c)Section 13(2)Section 13(2)(a)Section 13(3)Section 13(3)(e)Section 143(3)

…आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी वी दुगा" राव,"या"यक सद"य एवं "ी जी. मंजुनाथ, लेखा सद"य के सम" BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI G. MANJUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 2915, 3114, 3115/CHNY/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18 M/s. Jaya Educational Trust, The DCIT, No.8, 2nd Main Road, v. Central Circle 1(2), Krishnapuram, Chennai. Thiruninravur, Chennai – 602 024. PAN: AAATJ 0369D (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri Y.…

Jaya Educational Trust, Chennai vs. DCIT Centrl Circle 1 (2), Chennai

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

ITA 3115/CHNY/2019[2013-14]Status: DisposedITAT Chennai16 Jul 2021AY 2013-14

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

For Appellant: Shri Y. Sridhar, CAFor Respondent: Shri S. Bharath, CIT
Section 11Section 12ASection 13(1)(c)Section 13(2)Section 13(2)(a)Section 13(3)Section 13(3)(e)Section 143(3)

…आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी वी दुगा" राव,"या"यक सद"य एवं "ी जी. मंजुनाथ, लेखा सद"य के सम" BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI G. MANJUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 2915, 3114, 3115/CHNY/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18 M/s. Jaya Educational Trust, The DCIT, No.8, 2nd Main Road, v. Central Circle 1(2), Krishnapuram, Chennai. Thiruninravur, Chennai – 602 024. PAN: AAATJ 0369D (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri Y.…

Jaya Educational Trust, Chennai vs. DCIT Centrl Circle 1 (2), Chennai

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

ITA 3114/CHNY/2019[2012-13]Status: DisposedITAT Chennai16 Jul 2021AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

For Appellant: Shri Y. Sridhar, CAFor Respondent: Shri S. Bharath, CIT
Section 11Section 12ASection 13(1)(c)Section 13(2)Section 13(2)(a)Section 13(3)Section 13(3)(e)Section 143(3)

…आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी वी दुगा" राव,"या"यक सद"य एवं "ी जी. मंजुनाथ, लेखा सद"य के सम" BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI G. MANJUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 2915, 3114, 3115/CHNY/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18 M/s. Jaya Educational Trust, The DCIT, No.8, 2nd Main Road, v. Central Circle 1(2), Krishnapuram, Chennai. Thiruninravur, Chennai – 602 024. PAN: AAATJ 0369D (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri Y.…

Jaya Educational Trust, Chennai vs. DCIT Centrl Circle 1 (2), Chennai

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

ITA 2915/CHNY/2019[2016-17]Status: DisposedITAT Chennai16 Jul 2021AY 2016-17

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

For Appellant: Shri Y. Sridhar, CAFor Respondent: Shri S. Bharath, CIT
Section 11Section 12ASection 13(1)(c)Section 13(2)Section 13(2)(a)Section 13(3)Section 13(3)(e)Section 143(3)

…आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी वी दुगा" राव,"या"यक सद"य एवं "ी जी. मंजुनाथ, लेखा सद"य के सम" BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI G. MANJUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 2915, 3114, 3115/CHNY/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18 M/s. Jaya Educational Trust, The DCIT, No.8, 2nd Main Road, v. Central Circle 1(2), Krishnapuram, Chennai. Thiruninravur, Chennai – 602 024. PAN: AAATJ 0369D (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri Y.…

DCIT (E)- 2(1), Mumbai vs. J.R.D Tata Trust, Mumbai

In the result, the appeal of Revenue is dismissed and that of the assessee is allowed

ITA 3154/MUM/2018[2012-13]Status: DisposedITAT Mumbai13 Sept 2019AY 2012-13

Bench: Sri Mahavir Singhaayakr Apila Sam./ Ita No. 3082/Mum/2018 (Inaqa-Arna Baya- / Assessment Year 2012-13) J.R.D Tata Trust, The Income Tax Officer, Bombay House, 24, Homi 2(4), Mody Street, Fort, [Now Assessed By The Mumbai-400 001 Deputy Commissioner Of Vs. Income-Tax (Exemptions)- 2(1), Mumbai, Piramal Chambers, Lalbaug, Parel, Mumbai-400 012 .. (P`%Yaqaai- / Respondent) (Apilaaqai- / Appellant) स्थायी लेखा िं./Pan No. Aaatt0165F

For Appellant: Shri Percy PardiwalaFor Respondent: Shri Rajat Mittal, DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 164

…आयकर अपीलीय अधिकरण “SMC” न्यायपीठ म ुंबई में। IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI श्री महावीर स िंह, न्याययक दस्य BEFORE SRI MAHAVIR SINGH, JUDICIAL MEMBER Aayakr ApIla saM./ ITA No. 3082/Mum/2018 (inaQa-arNa baYa- / Assessment Year 2012-13) J.R.D Tata Trust, The Income Tax Officer, Bombay House, 24, Homi 2(4), Mody Street, Fort, [Now assessed by the Mumbai-400 001 Deputy Commissioner of Vs. Income-tax (Exemptions)- 2(1), Mumbai, Piramal Chambers, Lalbaug, Parel, Mumbai-400 012 .. (p`%yaqaaI- / Respondent) (ApIlaaqaI- / Appellant) स्थायी लेखा िं./PAN No. AAATT0165F Aayakr ApIla saM./ ITA N…

J.R.D. Tata Trust, Mumbai vs. ITO (E) - 2(4) (Now Asssessed by the DCIT (E) 2(1), Mumbai

In the result, the appeal of Revenue is dismissed and that of the assessee is allowed

ITA 3082/MUM/2018[2012-13]Status: DisposedITAT Mumbai13 Sept 2019AY 2012-13

Bench: Sri Mahavir Singhaayakr Apila Sam./ Ita No. 3082/Mum/2018 (Inaqa-Arna Baya- / Assessment Year 2012-13) J.R.D Tata Trust, The Income Tax Officer, Bombay House, 24, Homi 2(4), Mody Street, Fort, [Now Assessed By The Mumbai-400 001 Deputy Commissioner Of Vs. Income-Tax (Exemptions)- 2(1), Mumbai, Piramal Chambers, Lalbaug, Parel, Mumbai-400 012 .. (P`%Yaqaai- / Respondent) (Apilaaqai- / Appellant) स्थायी लेखा िं./Pan No. Aaatt0165F

For Appellant: Shri Percy PardiwalaFor Respondent: Shri Rajat Mittal, DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 164

…आयकर अपीलीय अधिकरण “SMC” न्यायपीठ म ुंबई में। IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI श्री महावीर स िंह, न्याययक दस्य BEFORE SRI MAHAVIR SINGH, JUDICIAL MEMBER Aayakr ApIla saM./ ITA No. 3082/Mum/2018 (inaQa-arNa baYa- / Assessment Year 2012-13) J.R.D Tata Trust, The Income Tax Officer, Bombay House, 24, Homi 2(4), Mody Street, Fort, [Now assessed by the Mumbai-400 001 Deputy Commissioner of Vs. Income-tax (Exemptions)- 2(1), Mumbai, Piramal Chambers, Lalbaug, Parel, Mumbai-400 012 .. (p`%yaqaaI- / Respondent) (ApIlaaqaI- / Appellant) स्थायी लेखा िं./PAN No. AAATT0165F Aayakr ApIla saM./ ITA N…

CIT v. Audyogik Shikshan Mandal (261 Taxmann 12) — Cited in 19 Judgments | BharatTax