Commissioner of Income-tax v. Nizam's Suppl. Religious Endowment Trust

127 ITR 378High Court1981#1297 most cited

What is Commissioner of Income-tax v. Nizam's Suppl. Religious Endowment Trust authority for?

Income of a charitable trust, other than from a business undertaking covered by Section 11(4), is determined based on its books of account. Payments of income tax and wealth tax by the trust are considered an application of income for charitable purposes under Section 11.

87

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2012 to 2025.

Also referred to as

Nizam's Suppl. Religious Endowment Trust · 127 ITR 378 · Section 11 application of income · income determination charitable trust · Section 11(4) business income · income tax payment trust · wealth tax payment trust · trust books of account income · exemption Section 11 · charitable purpose expenses

Sections most often in play

Section 11Section 80GSection 11(1)Section 11(1)(a)Section 11(2)Section 11(5)Section 12ASection 2(45)

Issues it is cited on

section 2(45)section 11(1)(a)section 11(1)application of incomecapital expendituresection 11previous yearpersontotal incomeindiainterestbusiness

Judgments citing Commissioner of Income-tax v. Nizam's Suppl. Religious Endowment Trust

Agrasen Medical Relief & Research Society, Jaipur vs. ITO(E), Ward-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 115/JPR/2025[2017-18]Status: DisposedITAT Jaipur26 May 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 11Section 12ASection 12A(1)(ac)Section 142(1)Section 143(2)Section 143(3)Section 250Section 80G

…a fee paid and is not a penalty for violation of any law. The amount so paid is not excluded from application of income under the provisions of the Act. Hon’ble AP High Court in case of CIT Vs. Trustee of H.E.H.theNizam`s supplement religious Endowment Trust 127 ITR 378(AP)has held that expenses incurred by way of payment of income tax and wealth tax during the relevant year were incidental to the carrying out of the charitable purpose of the trust. Such payment was outgoings in that particular year and was incidental to the carrying out of the objects of the trust. Therefore, the same is to be considered as app…

Sri Srinivasa Trust, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(1), Bangalore

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

ITA 1076/BANG/2024[2021-2022]Status: DisposedITAT Bangalore18 Feb 2025AY 2021-2022

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Siva Prasad Reddy & Shri BalachandranFor Respondent: Ms. Nandini Das, CIT (DR)
Section 11Section 11(1)Section 11(1)(a)Section 12ASection 2(45)Section 80G

…of 20 method of determination of income of a trust. In holding so, we draw support and guidance from the judgment of Hon’ble High Court of Andhra Pradesh in the case of CIT Vs. Trustee of H.E.H. the Nizam's Supplemental Religious Endowment Trust reported in 127 ITR 378 wherein it was held as under: Undoubtedly, sub-section (4) of section 11 specifically lays the mode of determination of the income of the business undertaking of a trust. A similar provision is not to be found with regard to the other income of the trust. By an inferential process, it could be said that that mode of determination by the ITO was…

Sri Srinivasa Trust, Bangalore vs. Assistant Commissioner of Income Tax, Central Circle-2(1), Bangalore

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

ITA 1075/BANG/2024[2020-21]Status: DisposedITAT Bangalore18 Feb 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Siva Prasad Reddy & Shri BalachandranFor Respondent: Ms. Nandini Das, CIT (DR)
Section 11Section 11(1)Section 11(1)(a)Section 12ASection 2(45)Section 80G

…of 20 method of determination of income of a trust. In holding so, we draw support and guidance from the judgment of Hon’ble High Court of Andhra Pradesh in the case of CIT Vs. Trustee of H.E.H. the Nizam's Supplemental Religious Endowment Trust reported in 127 ITR 378 wherein it was held as under: Undoubtedly, sub-section (4) of section 11 specifically lays the mode of determination of the income of the business undertaking of a trust. A similar provision is not to be found with regard to the other income of the trust. By an inferential process, it could be said that that mode of determination by the ITO was…

Shri Trimbakeshwar De vs. Than Trust, Nashikvs.CIT (Exemption) Pune, Pune

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

ITA 1051/PUN/2024[2018-2019]Status: DisposedITAT Pune18 Dec 2024AY 2018-2019

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1051/Pun/2024

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Ajay Kumar Keshari
Section 11Section 142(1)Section 143(2)Section 143(3)Section 263

…s view, in the present case, to ascertain the commercial profits, what should be deducted is not the tax shown in the balance-sheet but the actual tax assessed on the income of the company". 13. In CIT v. Nizam's Supplemental Religious Endowment Trust [1981] 127 ITR 378, the Andhra Pradesh High Court, while dealing with the scope of s. 11(4) of the Act, had expressed the view that only such of the income which is left after deducting the expenditure or such of the 12 Shri Trimbakeshwar Devsthan Trust money which is left with th trust after meeting all the expenditure, that the surplus income can be arrived at i…

Deputy Commissioner of Income Tax, Pune vs. Mukund Bhavan Trust, Pune

In the result, the appeal of Revenue is partly allowed for statistical purposes

ITA 374/PUN/2017[2012-13]Status: DisposedITAT Pune10 Aug 2022AY 2012-13

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri V.L. JainFor Respondent: Shri Sardar Singh Meena
Section 11Section 12Section 12ASection 13Section 13(1)(c)Section 143(2)Section 143(3)

…expenditure by themselves for the purpose of the Trust, but an incidence of the income or accumulation of income, and as such, must be deducted from the income of the Trust [CIT vs. Trustees of H.E.H. the Nizam's Supplemental Religious Endowment Trust, (1981) 127 ITR 378 (A.P.)]. Further, in the case of CIT vs. Baroda Industrial Development Corporation Limited, (1986) 24 Taxman 36, the Gujarat High Court held that the Income Tax liability of a Charitable Trust has to be deducted as a necessary outgoing before the net income capable of obligation for the purpose of the Trust under Section 11(1)(a) of the Income-ta…

Deputy Commissioner of Income Tax (Exemptions), Circle-1, Bengaluru vs. Karnataka Industrial Areas Development Board, Bengaluru

In the result, both the appeals filed by revenue are dismissed

ITA 578/BANG/2021[2010-11]Status: DisposedITAT Bangalore05 Jan 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri
Section 11Section 11(1)(a)Section 143(3)Section 2(15)

…the income computed in the aforesaid manner, should be not less than 75 per cent. of the latter, if the trust is to get the full benefit of the exemption u/s. 11(1)." 20. In CIT v. Trustee of H. E. H. The Nizam's Supplemental Religious Endowment Trust [1981] 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in conformity with the principles of accountancy for the purpose of determining the income derived from the property held in trust. 21. In CIT v. Rao Bahadur Calavala Cunnan Chetty Charities [1982] 135 ITR 485 at 495, the Madras High Court observed : "The…

Deputy Commissioner of Income Tax (Exemptions), Circle-1, Bengaluru vs. Karnataka Industrial Areas Development Board, Bengaluru

In the result, both the appeals filed by revenue are dismissed

ITA 577/BANG/2021[2009-10]Status: DisposedITAT Bangalore05 Jan 2022AY 2009-10

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri
Section 11Section 11(1)(a)Section 143(3)Section 2(15)

…the income computed in the aforesaid manner, should be not less than 75 per cent. of the latter, if the trust is to get the full benefit of the exemption u/s. 11(1)." 20. In CIT v. Trustee of H. E. H. The Nizam's Supplemental Religious Endowment Trust [1981] 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in conformity with the principles of accountancy for the purpose of determining the income derived from the property held in trust. 21. In CIT v. Rao Bahadur Calavala Cunnan Chetty Charities [1982] 135 ITR 485 at 495, the Madras High Court observed : "The…

Deputy Commissioner of Income Tax (Exemptions), Circle-1, Bangalore vs. M/S. Green Wood High Trust, Bangalore

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

ITA 708/BANG/2020[2014-15]Status: DisposedITAT Bangalore25 Oct 2021AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year: 2014-15

For Appellant: Dr. Manjunath Karkihalli, D.RFor Respondent: Shri B.R. Sudheendra, A.R
Section 12A

…ome, computed in the aforesaid manner, should not be less than 75 per cent of the latter, if the trust is to get the full benefit of the exemption under section 11(1)." 13. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in conformity with the principles of accountancy for the purposes of determining the income derived from the property held in trust." 18. In view of the aforesaid findings of the learned Tribunal, allowing any expenditure of the earlier year which has bee…

The Deputy Commissioner of Income Tax (Exemptions), Circle- 1, Bangalore vs. M/S. Childrens Education Society, Bangalore

In the result, all the three appeals of the revenue are dismissed

ITA 699/BANG/2020[2017-18]Status: DisposedITAT Bangalore01 Sept 2021AY 2017-18

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Muzaffar Hussain, D.RFor Respondent: Shri V. Srinivasan, A.R
Section 11(1)(a)Section 12A

…of 6 computed in the aforesaid manner, should not be less than 75 per cent of the latter, if the trust is to get the full benefit of the exemption under section 11(1)." 13. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in conformity with the principles of accountancy for the purposes of determining the income derived from the property held in trust." 18. In view of the aforesaid findings of the learned Tribunal, allowing any expenditure of the earlier year which has been…

The Deputy Commissioner of Income Tax (Exemptions), Circle- 1, Bangalore vs. M/S. Childrens Education Society, Bangalore

In the result, all the three appeals of the revenue are dismissed

ITA 698/BANG/2020[2016-17]Status: DisposedITAT Bangalore01 Sept 2021AY 2016-17

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Muzaffar Hussain, D.RFor Respondent: Shri V. Srinivasan, A.R
Section 11(1)(a)Section 12A

…of 6 computed in the aforesaid manner, should not be less than 75 per cent of the latter, if the trust is to get the full benefit of the exemption under section 11(1)." 13. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in conformity with the principles of accountancy for the purposes of determining the income derived from the property held in trust." 18. In view of the aforesaid findings of the learned Tribunal, allowing any expenditure of the earlier year which has been…

The Deputy Commissioner of Income Tax (Exemptions), Circle- 1, Bangalore vs. M/S. Childrens Educations Society, Bangalore

In the result, all the three appeals of the revenue are dismissed

ITA 697/BANG/2020[2014-15]Status: DisposedITAT Bangalore01 Sept 2021AY 2014-15

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Muzaffar Hussain, D.RFor Respondent: Shri V. Srinivasan, A.R
Section 11(1)(a)Section 12A

…of 6 computed in the aforesaid manner, should not be less than 75 per cent of the latter, if the trust is to get the full benefit of the exemption under section 11(1)." 13. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in conformity with the principles of accountancy for the purposes of determining the income derived from the property held in trust." 18. In view of the aforesaid findings of the learned Tribunal, allowing any expenditure of the earlier year which has been…

The Deputy Commissioner of Income Tax (Exemptions), Circle -1, Bangalore vs. Sri Shridevi Charitable Trust, Bangalore

In the result appeal filed by revenue stands dismissed

ITA 696/BANG/2020[2017-18]Status: DisposedITAT Bangalore12 Jan 2021AY 2017-18

Bench: Shri. B. R. Baskaran & Smt. Beena Pillaiassessment Year : 2017-18

For Appellant: Shri C Sandeep, C.AFor Respondent: Shri Rajesh Kumar Jha, CIT (DR)
Section 11Section 11(1)(a)Section 11(1)(d)Section 143(3)

…come, computed in the aforesaid manner, should not be less than 75 per cent of the latter, if the trust is to get the full benefit of the exemption under section 11(1)." 13. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in conformity with the principles of accountancy for the purposes of determining the income derived from the property held in trust." 18. In view of the aforesaid findings of the learned Tribunal, allowing any expenditure of the earlier year which has been…

Deputy Commissioner of Income Tax(Exemptions), Vijayawada vs. Cargo Handling Private Workers Pool Trust, Visakhapatnam

In the result, appeals filed by the Revenue in ITA Nos

ITA 313/VIZ/2018[2011-2012]Status: DisposedITAT Visakhapatnam08 Jun 2020AY 2011-2012

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Dr. C.P. Rama Swami, AdvFor Respondent: Shri S.R.S. Narayan, CIT DR
Section 13(1)(c)Section 143(3)Section 164(2)

…erefore added the same to the total income of the assessee. 13. On appeal, ld. CIT(A) allowed these payments by following the decision of the Hon'ble Andhra Pradesh High Court in the case of CIT Vs. Trustees of H.E.H. the Nizams Supplemental Religious [(1981) 127 ITR 378 (A.P.)] as an application of income. 14. Before us, ld. counsel for the assessee has submitted that coordinate bench of the tribunal in assessee’s own case in ITA No. 525/VIZ/2014 by common order dated 01/07/2016 has 7 ITA Nos. 312-314/VIZ/2018 (M/s. Cargo Handling Pvt. Workers Pool Trust) considered the issue and held that income-tax payment m…

Deputy Commissioner of Income Tax(Exemptions), Vijayawada vs. Cargo Handling Private Workers Pool Trust, Visakhapatnam

In the result, appeals filed by the Revenue in ITA Nos

ITA 312/VIZ/2018[2008-2009]Status: DisposedITAT Visakhapatnam08 Jun 2020AY 2008-2009

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Dr. C.P. Rama Swami, AdvFor Respondent: Shri S.R.S. Narayan, CIT DR
Section 13(1)(c)Section 143(3)Section 164(2)

…erefore added the same to the total income of the assessee. 13. On appeal, ld. CIT(A) allowed these payments by following the decision of the Hon'ble Andhra Pradesh High Court in the case of CIT Vs. Trustees of H.E.H. the Nizams Supplemental Religious [(1981) 127 ITR 378 (A.P.)] as an application of income. 14. Before us, ld. counsel for the assessee has submitted that coordinate bench of the tribunal in assessee’s own case in ITA No. 525/VIZ/2014 by common order dated 01/07/2016 has 7 ITA Nos. 312-314/VIZ/2018 (M/s. Cargo Handling Pvt. Workers Pool Trust) considered the issue and held that income-tax payment m…

ITO(E), WD-1(4), Kolkata vs. Panchajanya Trust, Kolkata

In the result, the appeal of the Assessee is allowed and the appeal of the Revenue is dismissed

ITA 1994/KOL/2017[2014-15]Status: DisposedITAT Kolkata01 Oct 2019AY 2014-15

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1841/Kol/2017 ("नधा"रणवष" / Assessment Year: 2014-15)

For Appellant: Shri S.K. Das, FCAFor Respondent: Shri Robin Chowdhury, DR
Section 11Section 11(1)(d)Section 12(1)Section 143(3)

…ees, taxes and legal expenses, etc., it could not be said that the income derived from the trust property was not applied exclusively to religious and charitable purposes. 6. In CIT v. Trustee of H.EH. the Nizam's Supplemental Religious Endowment Trust [1981] 127 ITR 378 (AP), it has been held that with regard to the income of the trust as such, it is the accounts of the trust alone that had to be taken into consideration. It was held that expenses incurred and by way of payments of income-tax and wealth-tax during the relevant year were incidental to the carrying out of the charitable purposes of the trust. Such…

Panchajanya Trust, Kolkata vs. ITO, (Exemption), Ward-1(4), Koklata, Kolkata

In the result, the appeal of the Assessee is allowed and the appeal of the Revenue is dismissed

ITA 1841/KOL/2017[2014-15]Status: DisposedITAT Kolkata01 Oct 2019AY 2014-15

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1841/Kol/2017 ("नधा"रणवष" / Assessment Year: 2014-15)

For Appellant: Shri S.K. Das, FCAFor Respondent: Shri Robin Chowdhury, DR
Section 11Section 11(1)(d)Section 12(1)Section 143(3)

…ees, taxes and legal expenses, etc., it could not be said that the income derived from the trust property was not applied exclusively to religious and charitable purposes. 6. In CIT v. Trustee of H.EH. the Nizam's Supplemental Religious Endowment Trust [1981] 127 ITR 378 (AP), it has been held that with regard to the income of the trust as such, it is the accounts of the trust alone that had to be taken into consideration. It was held that expenses incurred and by way of payments of income-tax and wealth-tax during the relevant year were incidental to the carrying out of the charitable purposes of the trust. Such…

Deputy Commissioner of Income Tax (E) Circle-1, Bangalore vs. M/S Karnataka Jesuit Educational Society, Bangalore

In the result appeal filed by revenue stands dismissed

ITA 1383/BANG/2018[2013-14]Status: DisposedITAT Bangalore24 Jul 2019AY 2013-14

Bench: Shri B.R.Baskaran & Smt Beena Pillai, Judical Member

For Appellant: Smt. Sheetal Borkar, AdvocateFor Respondent: Miss. Neera Malhotra, CIT
Section 11Section 12Section 143Section 15Section 70Section 80

…come, computed in the aforesaid manner, should not be less than 75 per cent of the latter, if the trust is to get the full benefit of the exemption under section 11(1)." 12. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in conformity with the principles of accountancy for the purposes of determining the income derived from the property held in trust.' 18. In view of the aforesaid findings of the learned Tribunal, allowing any expenditure of the earlier year which has been…

Nemi Chand Jain Educational Society, New Delhi vs. ITO, Ward- 2(4), New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 7018/DEL/2018[2015-16]Status: DisposedITAT Delhi06 May 2019AY 2015-16
For Appellant: Sh. K. Sampath, Adv. &For Respondent: Sh. S. L. Anuragi, Sr. DR
Section 10Section 11Section 11(1)Section 11(1)(a)Section 11(7)

…ied towards the charitable objects is subject to statutory set offs. It was submitted that the Hon’ble Andhra Pradesh High Court in the case of COMMISSIONER OF INCOME TAX (APPEALS) Vs Trustees of H.E.H The Nizam’s Supplemental Religious Endowment Trust (1981) 127 ITR 378 (AP) observed that with regard to the income of the Trust as such, it was the accounts of the Trust alone which had to be taken into consideration. That meant that statutory computation of income had no relevance. The reliance was placed on the decision of Hon’ble Madras High Court in the case of COMMISSIONER OF INCOME TAX (APPEALS) Vs Rao Bahadu…

M/S Shrimad Rajchandra Gyan Mandir Trust, Hubli vs. The Assistant Commissioner of Income Tax Circle-3(1), Hubli

In the result, assessee’s appeal for Assessment

ITA 39/BANG/2019[2011-12]Status: DisposedITAT Bangalore03 May 2019AY 2011-12

Bench: Shri Jason P. Boazassessment Year : 2011-12 M/S. Shrimad Rajchandra Gyan Vs. Assistant Commissioner Of Mandir Trust, Income-Tax, Beside Sbi, Zonal Office, Circle-3(1), Kusagal Road, Keswapur, Hubli. Hubballi – 580 023. Pan : Aacts 4573 L Appellant Respondent Assessee By : Smt. Sowmya, Advocate Revenue By : Shri. Sumer Singh Meena, Addl. Cit Date Of Hearing : 23.04.2019 Date Of Pronouncement : 03.05.2019 O R D E R

For Appellant: Smt. Sowmya, AdvocateFor Respondent: Shri. Sumer Singh Meena, Addl. CIT
Section 11(2)Section 12ASection 143(3)Section 234B

…come, computed in the aforesaid manner, should not be less than 75 per cent of the latter, if the trust is to get the full benefit of the exemption under section 11(1)." 13. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the 13. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in conformity with principles of accountancy for the purposes of det…

The ITO, (Exemptions), Ward, Surat vs. Shree Ambika Niketan Trust, Surat

In the result, the appeal of the revenue is dismissed

ITA 667/AHD/2017[2013-14]Status: DisposedITAT Surat24 Oct 2018AY 2013-14

Bench: Shri Rajpal Yadav & Shri Amarjit Singhअपील सं./Ita No.667/Ahd/2017 "नधा"रण वष"/Asstt. Year:2013-2014 Income Tax Officer, Shree Ambika Niketan Trust, [Exemption] Ward, Surat, H.No.13/52, Vs. Surat. C/0 Ambika Niketan Mandir, Khan Saheb Ni Wadi, Athwalines, Surat-395001. Pan Aabts2849C (Applicant) (Responent) Revenue By : Shri Prasanjit Singh, Cit,Dr : Assessee By Kruti Kothari, C.A सुनवाई क" तार"ख/Date Of Hearing : 15/11/2018 घोषणा क" तार"ख /Date Of Pronouncement: 16/11/2018 आदेश/O R D E R Per Amarjit Singh:

For Respondent: Shri Prasanjit Singh, CIT,DR
Section 11Section 143(2)Section 143(3)Section 70

…uent year. The expenditure that can be so adjusted can only be expenditure on religious and charitable purposes and no other. The High Court relied on the following decisions CIT v/s Trustees of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378 ( AP) TC 23 R 083 CIT v/s Society of the Sisters of St Anne ( 1984) 39 CTR ( kar) 9; (1984) 146 ITR 28 (Kar) TC 2 R 978 CIT v/s Maharana of Mewar Charitable Foundation (1987) 60 CTR (Raj) 40; | (1987) 164 ITR 439 ( Raj) TC 23 R 1198 CIT v/s Shri Plot Swetamber Murti Pujak Jain Mandal ( 1994) 119 CTR ( Guj) 114; (1995) 211 ITR 293 ( Guj) TC 23R 12…