Which sections of the Income Tax Act does CIT v. Institute of Banking Personnel Selection come up under?

It is most often cited in judgments turning on Section 143(3), Section 11, Section 12A, Section 147, Section 11(1)(a), Section 11(6).

CIT v. Institute of Banking Personnel Selection

Q: How many judgments cite CIT v. Institute of Banking Personnel Selection?

398 judgments on BharatTax cite CIT v. Institute of Banking Personnel Selection (264 ITR 110), spanning 2012 to 2026.

264 ITR 110High Court2003#181 most cited

What is CIT v. Institute of Banking Personnel Selection authority for?

Depreciation is allowable on assets for which the cost has been fully allowed as an application of income under Section 11 in previous years, when computing the income of a charitable trust. Charitable trusts are also entitled to carry forward their deficit.

398

judgments rely on this decision, according to BharatTax’s citation analysis of 372,576 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Institute of Banking Personnel Selection · Section 11 · Section 11(1) · depreciation allowance for trusts · application of income · capital expenditure trusts · carry forward of deficit · charitable trust exemption · computing trust income

Sections most often in play

Section 143(3)Section 11 Section 12A Section 147 Section 11(1)(a)Section 11(6)Section 12 Section 13(8)

Issues it is cited on

section 11(1)(a)section 11(1)application of income capital expenditure section 12a section 11 section 10 section 12 previous year section 13 person section 25

Judgments citing CIT v. Institute of Banking Personnel Selection

ITO (E), Ward- 1(3), New Delhi vs. Dr. Bhai Mohan Singh Foundation, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 6249/DEL/2017[2013-14]Status: DisposedITAT Delhi08 Jul 2020AY 2013-14

Bench: Shri G.S. Pan Before Shri G.S. Pannu & Before Shri G.S. Pan Before Shri G.S. Pan & Shri Sudhanshu Srivastavashri Sudhanshu Srivastava Shri Sudhanshu Srivastava Shri Sudhanshu Srivastava

For Appellant: Ms. Nidhi Srivastava, CIT-DRFor Respondent: Shri Gaurav Jain, Advocate and Shri Himanshu Aggarwal, CA

Section 11Section 12A

…IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI BENCH ‘ DELHI DELHI BENCH ‘ BENCH ‘B’ : NEW DELHI BENCH ‘ ’ : NEW DELHI ’ : NEW DELHI ’ : NEW DELHI (THROUGH VIDEO CONFERENCING) (THROUGH VIDEO CONFERENCING) (THROUGH VIDEO CONFERENCING) (THROUGH VIDEO CONFERENCING) BEFORE SHRI G.S. PAN BEFORE SHRI G.S. PANNU, VICE PRESIDENT AND BEFORE SHRI G.S. PAN BEFORE SHRI G.S. PAN VICE PRESIDENT AND VICE PRESIDENT AND VICE PRESIDENT AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER SHRI SUDHANSHU SRIVASTAVA , JUDICIAL…

Deputy Commissioner of Income-Tax, (Exemption) Circle, Pune vs. Vidya Pratishthan, Pune

In the result, the appeal of the Revenue for A

ITA 2550/PUN/2017[2009-10]Status: DisposedITAT Pune10 Jun 2020AY 2009-10

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita Nos.2549 & 2550/Pun/2017 धनधाारण वषा / Assessment Years : 2008-09 & 2009-10

For Appellant: Shri Pratik SandbhorFor Respondent: Shri S.P. Walimbe

Section 11Section 11(1)Section 12ASection 147Section 32Section 32(1)

…me. The assessee acquired assets with the exempt funds of the assessee. The assessee also claimed depreciation on the said assets relying on the Hon‟ble Bombay High Court judgement in the case of CIT vs. Institute of Banking, Personnel Selection (IBPS) [2013] 264 ITR 110 (Bom.). However, the Assessing Officer denied the benefit of claim of depreciation as per the discussion given in para No.5 and 6 of his order. 4. During the first appellate proceedings, the assessee filed a written submission which is extracted in para 4 of the order of the CIT(A). In the said written submission, the assessee relied on the seri…

Deputy Commissioner of Income-Tax, (Exemption) Circle, Pune vs. Vidya Pratishthan, Pune

In the result, the appeal of the Revenue for A

ITA 2549/PUN/2017[2008-09]Status: DisposedITAT Pune10 Jun 2020AY 2008-09

For Appellant: Shri Pratik SandbhorFor Respondent: Shri S.P. Walimbe

Section 11Section 11(1)Section 12ASection 147Section 32Section 32(1)

Shree Ram Trust, Kolkata vs. I.T.O., Ward-1(3), Kolkata

In the result, the appeal of the assessee is partly allowed

ITA 2496/KOL/2019[2012-13]Status: DisposedITAT Kolkata22 May 2020AY 2012-13

Bench: Shri A. T. Varkey, Jm ]

Section 11(1)Section 11(1)(a)Section 11(1)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A-SMC”BENCH: KOLKATA [Before Shri A. T. Varkey, JM ] I.TA No. 2496/Kol/2019 A.Y 2012-13 Shree Ram Trust Vs. I.T.O ( E), Ward 1(3), Kolkata PAN: AADTS5275L Appellant Respondent Date of Hearing 03.02.2020 Date of Pronouncement 22 .05.2020 For the Appellant Shri P.R. Kothari, FCA, ld.AR For the Respondent Shri Jayanta Khanra, JCIT, ld. Sr.DR ORDER PER SHRI A.T. VARKEY, JM This appeal is preferred by the assessee against the order of Ld. CIT (A), 25, Kolkata dated 18.10.2019 for the assessment year 2012-13. 2. The assessee has raised the following grounds of appeal:- GROUN…

DCIT, CC - 7(1), Mumbai vs. D.Y Patil Sports Academy, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 6882/MUM/2018[2014-15]Status: DisposedITAT Mumbai05 Feb 2020AY 2014-15

Bench: Shri Saktijit Dey & Shri G. Manjunath

For Appellant: NoneFor Respondent: Shri Kamal Mangal

Section 11Section 12A

…ting to ` 9,32,09,946. The assessee challenged the aforesaid disallowance before the first appellate authority. 4. The learned Commissioner (Appeals) having noticed that the Hon'ble Jurisdictional High Court in CIT v/s Institution of Banking Personal, [2003] 264 ITR 110 (Bom.) has allowed similar claim and in assessee’s own case in assessment year 2010–11 and 2011–12, the Tribunal has allowed assessee’s claim of carry forward of excess 3 D.Y. Patil Sports Academy expenditure/deficit, allowed assessee’s claim of carry forward of excess expenditure/deficit to subsequent assessment year. 5. When the appeal was c…

Deputy Commissioner of Income Tax Central Circle-1, Mangalore vs. M/S Navodaya Grama Vikas Charitable Trust, Bangalore

ITA 1108/BANG/2018[2014-15]Status: DisposedITAT Bangalore29 Jan 2020AY 2014-15

Bench: Shri N.V. Vasudevan, Vice- & Shri B.R.Baskaran

For Appellant: Smt. Sowmya Achar, Addl.CIT(DR)(ITAT), BengaluruFor Respondent: Shri V. Srinivasan, Advocate

Section 11(1)(a)

…as held in the case of CIT Vs. Maharana of Mewar Charitable Foundation 164 ITR 439 (Raj) & CIT Vs. Shri Plot Swetamber Murti Pujak Jain Mandal 211 ITR 293 (Guj.). In CIT Vs. Institute ITA Nos. 1108 & 1109/Bang/2018 Page 3 of 4 of Banking Personnel Selection 264 ITR 110 (Bom) it was held that in case of charitable trust whose income is exempt under s. 11, excess of expenditure in the earlier years can be adjusted against income of subsequent years and such adjustment would be application of income for subsequent years and that depreciation is allowable on the assets the cost of which has been fully allowed as ap…

Deputy Commissioner of Income Tax Central Circle-1(1), Bangalore vs. M/S Navodaya Grama Vikas Charitable Trust, Bangalore

ITA 1109/BANG/2018[2009-10]Status: DisposedITAT Bangalore29 Jan 2020AY 2009-10

Bench: Shri N.V. Vasudevan, Vice- & Shri B.R.Baskaran

For Appellant: Smt. Sowmya Achar, Addl.CIT(DR)(ITAT), BengaluruFor Respondent: Shri V. Srinivasan, Advocate

Section 11(1)(a)

Nandalal Tolani Charitable Trust, Mumbai vs. ADIT (E) - II (2), Mumbai

In the result, appeal of the assessee is dismissed

ITA 6949/MUM/2018[2011-12]Status: DisposedITAT Mumbai15 Jan 2020AY 2011-12

Bench: Shri Mahavir Singh, Jm & Shri M.Balaganesh, Am M/S. Nandlal Tolani Vs. Asst. Director Of Income Charitable Trust Tax (Exem.)Ii(2), Mumbai 10-A, Bakhtawar R.P.Goenka Marg Nariman Point, Mumbai – 400 021 Pan/Gir No. Aaatn0043Q (Appellant) .. (Respondent)

Section 11Section 11(2)Section 143(3)Section 2(45)Section 24Section 45

…ritable or religious trust/institution which has to be applied for the said purposes, has been a subject matter of a number of decisions, as by the Hon'ble jurisdictional High Court in the case of CIT vs. Institute of Banking Personnel Selection (IBPS) [2003] 264 ITR 110 (Bom). This is even otherwise patent in as much as a trust could only apply the income as vailable with it, i.e., as arrived at following the accepted principles of commercial accounting. The computation provisions of the Act do not come into play, so that the said computation of the would be de hors the same. This would of course be subject to t…

Improvement Trust, Fatehabad vs. ITO (Exemptions), Rohtak

Appeal of the assessee is partly allowed

ITA 6334/DEL/2016[2013-14]Status: DisposedITAT Delhi14 Jan 2020AY 2013-14

Bench: Shri Prashant Maharishi & Shri K.N.Charyimprovement Trust Fatehabad, Vs. Ito(Exemptions), Near Bus Stand, Rohtak Fatehabad Pan: Aaati6435P (Appellant) (Respondent)

For Appellant: Shri Ashok Goyal, AdvFor Respondent: Shri Sanjog Kapoor, Sr. DR

Section 11Section 12Section 143Section 24

…ritable or religious trust/institution which has to be applied for the said purposes, has been a subject matter of a number of decisions, as by the hon'ble jurisdictional High Court in the case of CIT vs. Institute of Banking Personnel Selection (IBPS) [2003] 264 ITR 110 (Bom). This is even otherwise patent inasmuch as a trust could only apply the income as available with it, i.e., as arrived at following the accepted principles of commercial accounting. The computation provisions of the Act do not come into play, so that the said computation of the would be de hors the same. This would of course be subject to th…

I.T.O. - (Exemptions) - 1(1), Mumbai vs. Empire Foundation, Mumbai

The appeal stands dismissed

ITA 6858/MUM/2018[2014-15]Status: DisposedITAT Mumbai05 Dec 2019AY 2014-15

Bench: Hon’Ble Shri C.N. Prasad, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ I.T.A. No.6858/Mum/2018 (िनधा"रण वष" / Assessment Year: 2014-15) Dcit (Exemption)-1(1) Empire Foundation Room No.506, 5Th Floor C/O. Vibgyor High बनाम/ Piramal Chambers, Lalbaug Motilal Nagar-1 Vs. Mumbai-400 012. Srirang Sabde Marg Goregaon (W), Mumbai-400 104. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaate-3549-C (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : None Revenue By : Shri Maurya Pratap – Ld. Dr

For Appellant: NoneFor Respondent: Shri Maurya Pratap – Ld. DR

Section 11(1)(a)Section 12ASection 143(3)

…ar :2014-15 to its receipts since the trusts are not running on expectation of future profits / income. 4. The learned first appellate authority, relying upon the decision of jurisdictional Bombay High Court rendered in CIT Vs. Institute of Banking Personnel [264 ITR 110], opined that deficit could be carry forward for setting off against income of subsequent years. Hence, Ld. AO was directed to allow the carry forward of the deficit. Aggrieved, the revenue is in further appeal before us. 5. Upon due consideration, we find that learned first appellate authority has merely followed the ratio of stated decision ren…

Shantaram Bhat Charitable Trust, Mumbai vs. CIT (A)- 1 Mumbai, Mumbai

In the result, appeal by the assessee stands partly allowed

ITA 3364/MUM/2018[2013-14]Status: DisposedITAT Mumbai25 Nov 2019AY 2013-14

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

Section 11Section 11(1)Section 2(45)Section 24Section 5

…ouse property is totally unsustainable in law. As a matter of fact, the proposition that income has to be computed as per provisions of the Act even in the case of Trust was approved by Hon'ble Bombay High Court in the case of Institute of Banking Personnel (264 ITR 110), wherein capital expenditure for acquiring asset which was already shown as application of income was held to be eligible for depreciation which was denied by the Revenue. In this view of the matter in our considered opinion the assessee is entitled to deduction u/s. 24 of the Act. Following the precedent as above, we direct accordingly. Since w…

Deputy Commissioner of Income-Tax, (Exemption) Circle, Pune vs. International Institute of Information Technology, Pune

In the result, the appeal of the Revenue is dismissed

ITA 2163/PUN/2017[2010-11]Status: DisposedITAT Pune19 Nov 2019AY 2010-11

For Appellant: Shri Nikhil PathakFor Respondent: Shri Hoshang B. Irani

…both the sides on this issue, we perused the order of the CIT(A) and find the decision taken by the CIT(A) is fair and reasonable as he followed the binding Jurisdictional High Court’s judgement in the case of CIT vs. Institute of Banking Personnel Selection, 264 ITR 110 (Bom) and others. Further, we find similar views taken in favour of the assessee by the Pune Bench of the Tribunal in the case of Maharshi Karve Stree Shikshan Samstha Karvenagar vs. ITO, 101 taxman.com 175 (Pune-Trib.). Considering the settled nature of the issue at the level of Hon’ble Jurisdictional High Court in the case of Mumbai Education T…

Vipassana Research Institute, Mumbai vs. ITO (Exemption) - 2(4), Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 2532/MUM/2018[2012-13]Status: DisposedITAT Mumbai15 Nov 2019AY 2012-13

Bench: Shri. Vikas Awasthy & Shri G. Manjunathavipassana Research Institute Vs. Ito(Exemptions)-2(4) 2Nd Floor, Green House Piramal Chambers Green Street, Fort Lalbaug, Parel Mumbai-400 023 Mumbai-400 012 Pan/Gir No.Aaatv1217E (Appellant) .. (Respondent)

Section 10(34)Section 10(35)Section 11Section 11(1)(a)Section 12ASection 43

…appellate order partly allowed, appeal filed by the assessee, where he had allowed relief towards depreciation on fixed assets by following decision of Hon’ble Bombay High Court, in the case of CIT vs Institute of Banking and Personnel Selection (IBPS) (2003) 264 ITR 110. He has also allowed the claim of the assessee to carry forward deficit of the year to subsequent year by following the decision of Hon’ble Bombay High Court, in the case of CIT vs IBPS (supra). Similarly, he had allowed relief to the assessee, in respect of dividend income exempt u/s 10(34) of the I.T.Act 1961. However, confirmed the findings of…

The Assistant Commissioner of Income Tax (Exemption) Circle- 1, Mangalore vs. M/S Hubli Dharwad Urban Development Authority, Hubli

In the result, the appeal filed by the revenue stands partly allowed for statistical purposes in the terms indicated above

ITA 1668/BANG/2017[2012-13]Status: DisposedITAT Bangalore08 Nov 2019AY 2012-13

Bench: Shri N.V. Vasudevan, Vice- & Shri Arun Kumar Garodiaassessment Year : 2012-13 The Assistant M/S. Hubli Dharwad Urban Commissioner Of Development Authority, Income Tax Vs. Navanagar, (Exemptions), Hubbali. Circle – 1, Pan: Aaalh0053J Mangaluru. Appellant Respondent Assessee By : Shri Gangadhar .J.M, Advocate Revenue By : Shri C.H. Sundar Rao, Cit (Dr) Date Of Hearing : 04.11.2019 Date Of Pronouncement : 08.11.2019

For Appellant: Shri Gangadhar .J.M, AdvocateFor Respondent: Shri C.H. Sundar Rao, CIT (DR)

Section 10(2)Section 11Section 12ASection 13(8)Section 2(15)Section 251(1)(a)Section 35Section 35(1)(iv)

…ncome for purposes of section 11. The questions proposed have, thus, to be answered against the Revenue and in favour of the assessee". 14. Similar views have been taken by different High Courts as under: CIT Vs Institute of Banking Personnel Selection [2003] 264 ITR 110 (Bom)- DIT (E) Vs Framjee Cawasjee Institute [1993] 109 CTR 463 (Bom)- CIT Vs Tiny Tots Education Society [2011] 330 ITR 21 (P&H) 15. As held by the Hon'ble HC of Punjab and Haryana in the case of Market Committee, Pipli, the assessee has not claimed double deduction on account of depreciation. The income of assessee being exempt, the assessee ha…

ACIT, New Delhi vs. Centre for Advanced Education, New Delhi

In the result, the appeal of the revenue is dismissed

ITA 640/DEL/2017[2012-13]Status: DisposedITAT Delhi22 Oct 2019AY 2012-13

For Appellant: NoneFor Respondent: Ms. Nidhi Srivastava, CIT DR

Section 11Section 11(1)Section 12ASection 2(15)

…stration u/s 12AA, has been settled by the judgment of Hon’ble Supreme Court. The Hon’ble Apex Court upheld the decision of the Bombay High Court (Bombay HC) in the case of Commissioner of Income Tax v. Institute of Banking Personnel Selection (IBPS), ([2003] 264 ITR 110 (Bombay)) wherein it was held that the income of an Institution was to be computed on commercial principles, after providing for allowance for normal depreciation. Similar, decision has been delivered in the case of Rajasthan and Gujarati Charitable Foundation Poona which is a charitable institution registered under Section 12A of the Act. In 4…

Breach Candy Hospital Trust, Mumbai vs. ACIT (E) - 1(1), Mumbai

In the result, the appeal is allowed as indicated above

ITA 3698/MUM/2018[2012-13]Status: DisposedITAT Mumbai11 Oct 2019AY 2012-13

Bench: S/Shri Saktijit Dey & Manoj Kumar Aggarwalassessment Year 2012-13 Breach Candy Hospital Trust, Acit (E)- 1(1), 60A, Bhulabhai Desai Road, Mumbai Vs. Mumbai 400 012. Pan Aaatb0214D (Appellant) (Respondent)

For Appellant: Shri Ketan Ved &For Respondent: Ms Samatha Mullamudi

Section 11Section 12ASection 154Section 32

…the year in which the assets were acquired, the assessee would not be eligible for depreciation on such assets. While doing so, he observed that the decision of Hon’ble Bombay High Court in the case of CIT vs. Institute of Banking Personnel Selection (2003) 264 ITR 110, would not be applicable as it has not taken note of the ratio laid down in the case of Escorts Ltd. (supra). Accordingly, he disallowed assessee’s claim of depreciation. Being aggrieved, assessee challenged the disallowance before learned CIT(A). 4. After taking note of the decision of Hon’ble Supreme Court in the case of CIT vs. Rajasthan &…

The DDIT (Exemp.), Ahmedabad vs. Adarsh Foundation, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 1858/AHD/2013[2009-10]Status: DisposedITAT Ahmedabad20 Sept 2019AY 2009-10

Bench: Shri O. P Meena & Ms. Madhumita Royआ.अ.सं/.I.T.A No.1858/Ahd/2013 िनधा"रणवष"/Assessment Year:2009-10 बनाम Deputy Director Of Income Tax Adarsh Foundation, Vs. (Exemption), Ahmedabad C/O Sal Hospital & Medical Institution, Opp. Doordarshan Tower, Drive- In-Road, Thaltej, Ahmedabad Pan:Aaa Ta2 111 J अपीलाथ" Appellant ""यथ"/Respondent

Section 11(1)(a)Section 12ASection 13Section 32

…ilal DDIT (E) v. Adarsh Foundation /I.T.A.No. 1858/AHD/2013/A.Y. 2009-10 Pg 24 Ranchhoddas Vishram Bhavan Trust 198 ITR 598 (Guj) has allowed the claim of depreciation of trust. Similarly in following cases CIT vs. Institute of Banking Personnel Selection 264 ITR 110 (Bom), CIT vs. Raipur Pallotine Society 180 ITR 579 (MP) and CIT vs. Market Committee Pipli 330 ITR 16 (P & H) the claim of depreciation trust has been held as allowable. 18. Considering these facts and placing reliance on the aforesaid case laws and following decision of ITAT ‘C’ Bench, Ahmedabad decision in the case of Adharshila Education…

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

…e was no express provisions in the IT Act, 1961 permitting allowance of such claim.” 23. At the outset, it is noted that this issue is covered by the decision of Hon’ble Bombay High Court in the case of CIT vs. Institute of Banking Personnel Selection (2003) 264 ITR 110 (Bom.) and also in assessee’s own case in ITA No 7122/Mum/2017 for AY 2011-12, wherein Tribunal has considered the judgement of Hon’ble Bombay High court and other judgements and allowed the claim of the assessee by dismissing the appeal of Revenue vide Para 5 as under: - “5. We have heard the rival submissions and perused the relevant material…

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

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

DCIT (Exemption), New Delhi vs. India Trade Promotion Org., New Delhi

ITA 3359/DEL/2016[2009-10]Status: DisposedITAT Delhi13 Sept 2019AY 2009-10

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Smt. Anju Goel, CAFor Respondent: Smt. Aparna Karan, CIT DR

Section 10Section 10(23)(iv)Section 11Section 12ASection 2Section 2(15)Section 25

…1 (P&H), Commissioner of Income Tax vs. Sheth Manilal Ranchhoddas Vishram Bhavan Trust, (1992) 198 ITR 598 (Guj.), Commissioner of Income Tax vs. Raipur Pallottine Society, (1989) 180 ITR 579 (M.P.), Commissioner of Income Tax vs. Institute of Banking, (2003) 264 ITR 110 (Bom), and CIT vs. Shakuntala Tharal Charitable Foundation, (2013) 358 ITR 452 (MP). 15. Kerala High Court was also conscious of the said decisions and the fact that Section 11(1)(a) had been interpreted in a different manner. It was in these circumstances that the Kerala High Court in the last portion of paragraph 6, as quoted above, has stated…