Director of Income Tax (Exemption) v. ACME Educational Society

326 ITR 146High Court2010#3684 most cited

What is Director of Income Tax (Exemption) v. ACME Educational Society authority for?

An interest-free loan provided by one charitable society to another, both registered under Section 12AA and possessing similar objectives, does not contravene Section 13(1)(d) read with Section 11(5) of the Income Tax Act, as such loans are not classified as investments or deposits.

32

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2012 to 2024.

Also referred to as

ACME Educational Society · Section 13(1)(d) · Section 11(5) · charitable trust · interest-free loan · investment · deposit · Section 12AA

Sections most often in play

Section 11Section 11(5)Section 13(1)(d)Section 145(3)

Issues it is cited on

prescribedpersonsection 143(3)indianfacbusinessdocumentinterest

Judgments citing Director of Income Tax (Exemption) v. ACME Educational Society

Deputy Commissioner of Income Tax, Chandigarh vs. James Hotels Ltd, Chandigarh

ITA 552/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh01 Oct 2024AY 2012-13

Bench: The Said Resolution To Enhance Authorized Share Capital.

For Appellant: Shri R.K. KapoorFor Respondent: Shri Rohit Sharma, CIT, DR
Section 143(2)Section 269SSection 271D

…r to a loan or a deposit within the meaning of section 269SS of Income Tax Act. While arriving at the conclusions Hon'ble Delhi High Court has followed the principle pronounced by the same Court in the case of DIT exemption vs. Acme Educational Society (2010) 326 ITR 146 (Delhi). 8.4 It was further submitted that there is no prohibition in the Companies Act, 1956 that the share application money cannot be received in cash by the assessee company. Further, there is also no prohibition that share application money cannot be received without having sufficient authorized capital. The only requirement under the Compan…

Assistant Commissioner of Income Tax, Exemptions, Circle, Jaipur, Jaipur Rajasthan vs. Navratan Vidha Mandir Shiksha Samiti, Jaipur Rajasthan

In the result appeal filed by the Department is dismissed and the C

ITA 201/JPR/2024[2012-13]Status: DisposedITAT Jaipur27 Sept 2024AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C.Parwal, CAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 11Section 11(5)Section 13(1)(d)Section 145(3)

…ven, was also an organization having registration under Section 12AAof the Act and objects of both the organizations were similar. Reliance was also placed on the decision of Hon'ble Delhi High Court in the case of DIT (Exemption) v. Acme Educational Society (326 ITR 146). It was decided by Hon'ble Delhi High Court held that interest-free loan given by the assessee- society to another society, having similar objects and registered under Section 12AA of the Act, did not violate Section 13(1)(d) read with Section 11(5) of the Act, since such loans were neither investments nor deposits. No doubt, the assessee here h…

DCIT Central Circle-2, Bhubaneswar vs. M/S. Hotel Sukhamaya Pvt. Ltd, Bhubaneswar

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

ITA 206/CTK/2022[2012-13]Status: DisposedITAT Cuttack18 Sept 2024AY 2012-13
Section 132Section 269SSection 271D

…lly the duty of the depositor to go to the banker or to the deposited, as the case may be, and make a demand for it. This judgment was approvingly cited by a Division Bench of this court in Director of Income Tax (Exemption) vs ACME Educational Society (2010) 326 ITR 146 (Del). In this decision, it was held that a loan grants temporary use of money, or temporary accommodation, and that the essence of a deposit is that there must be a liability to return it to the party by whom or on whose behalf it has been made, on fulfillment of certain conditions. If these tests are applied to the facts of the case before us,…

DCIT Central Circle-2, Bhubaneswar vs. M/S. Hotel Sukhamaya Pvt. Ltd, Bhubaneswar

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

ITA 205/CTK/2022[2009-10]Status: DisposedITAT Cuttack18 Sept 2024AY 2009-10
Section 132Section 269SSection 271D

…lly the duty of the depositor to go to the banker or to the deposited, as the case may be, and make a demand for it. This judgment was approvingly cited by a Division Bench of this court in Director of Income Tax (Exemption) vs ACME Educational Society (2010) 326 ITR 146 (Del). In this decision, it was held that a loan grants temporary use of money, or temporary accommodation, and that the essence of a deposit is that there must be a liability to return it to the party by whom or on whose behalf it has been made, on fulfillment of certain conditions. If these tests are applied to the facts of the case before us,…

Deputy Commissioner of Income Tax, Exemptions Circle, Chennai, Income Tax Department vs. The Indian Institute of Engineering Technology, Chennai

In the result the appeal of the Revenue dismissed

ITA 679/CHNY/2024[2012-13]Status: DisposedITAT Chennai30 Aug 2024AY 2012-13

Bench: Shri Mahavir Singh & Shri S.R. Raghunathaआयकर अपील सं./Ita No.679/Chny/2024 िनधा;रण वष; /Assessment Year: 2012-13 The Dy. Commissioner Of The Indian Institute Of Engineering Income Tax, Vs. Technology, Exemptions Circle, 363, Arcot Road, Kodambakkam, Chennai. Chennai – 600 024. [Pan: Aaatt 2768C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथH की ओर से/ Assessee By : Shri R. Vijayaraghavan, Advocate JkथH की ओर से /Revenue By : Shri N. Sanjay Gandhi, Jcit सुनवाई की तारीख/Date Of Hearing : 11.06.2024 घोषणा की तारीख /Date Of Pronouncement : 30.08.2024 आदेश / O R D E R Per S.R. Raghunatha, A.M : This Appeal By The Revenue Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), (Nfac), Delhi [Hereinafter “Cit(A)] In Din & Order No.Itba/Nfac/S/250/2023- 24/1059500064(1), Dated 09.01.2024. The Assessment Was Framed By The Assessing Officer For The Assessment Year 2012-13 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’), Vide Order Dated 20.03.2015. :- 2 -: 2. There Is A Delay Of 06 Days In Filing The Appeal By The Revenue.

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri N. Sanjay Gandhi, JCIT
Section 10Section 11Section 12ASection 13(1)Section 13(1)(c)Section 13(1)(d)Section 143(3)

…insubstantial. We are therefore not inclined to interfere with this part of the order of the Tribunal. We accordingly answer question No. 3 in the affirmative, that is, against the Revenue and in favour of the assessee. 2. DIT(E) Vs.ACME Education Society – 326 ITR 146 (Del) Loan given by a society to another educational society does not violate S.13(1)(d) r.w.s. 11(5) at Para 15, the Hon’ble High Court held as under: “15. Keeping in view the aforesaid exposition of law, we are of the opinion that interest-free loan of Rs. 90,50,000 given by the assessee-society to Nav Bharti Educational Society does not viola…

Commissioner of Income Tax vs. M/S Jamnalal Bajaj Foundation

ITA/808/2017HC Delhi31 May 2024

Bench: HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV,HON'BLE MR. JUSTICE YASHWANT VARMA

Section 11Section 11(1)Section 11(2)Section 11(3)(c)Section 12ASection 142(1)Section 143(1)Section 143(2)

…lhi High Court in Director of Income-tax (Exemption) v. Acme Educational Society (supra) holding that a loan is neither an investment nor a deposit. Where both the societies have similar 11 (2010) 326 ITR 146 12 2013 SCC OnLine All 14708 Digitally Signed By:KAMLESH KUMAR Signing Date:31.05.2024 14:45:18 Signature Not Verified ITA 808/2017 Page 23 of 24 objects and are registered under section 12A and have approvals under section 80G, interest-free loan cannot be treated as deposit or investment so as to attract section 11(5) of the Act.…

Commissioner of Income Tax vs. M/S Jamnalal Bajaj Foundation

ITA-808/2017HC Delhi31 May 2024
Section 11Section 11(1)Section 11(2)Section 11(3)(c)Section 12ASection 142(1)Section 143(1)Section 143(2)

…lhi High Court in Director of Income-tax (Exemption) v. Acme Educational Society (supra) holding that a loan is neither an investment nor a deposit. Where both the societies have similar 11 (2010) 326 ITR 146 12 2013 SCC OnLine All 14708 Digitally Signed By:KAMLESH KUMAR Signing Date:31.05.2024 14:45:18 Signature Not Verified ITA 808/2017 Page 23 of 24 objects and are registered under section 12A and have approvals under section 80G, interest-free loan cannot be treated as deposit or investment so as to attract section 11(5) of the Act.…

DCIT(E)- Circle- 1(1), New Delhi vs. Indian Broadcasting Foundation, New Delhi

Accordingly, the grounds are not sustainable and the appeal of revenue is dismissed

ITA 5589/DEL/2018[2015-16]Status: DisposedITAT Delhi08 Sept 2022AY 2015-16

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No. 5589/Del/2018, A.Y. 2015-16 Dcit(E) Vs. Indian Broadcasting Foundation B-304, 3Rd Floor Ansel Plaza Circle-1(1), E-2 Block, Pratyaksh Kar Bhawan, Khel, Dr. Shyama Prasad Mukherjee Gaon Marg, Civic Centre, New Delhi - 110049 New Delhi (Appellant) (Respondent)

Section 11Section 11(5)Section 12ASection 13(1)Section 13(1)(d)Section 143(3)Section 164(2)Section 25Section 250

…Public Charitable Trust [2001] 250 ITR 475 (Delhi), Anand Charitable Trust v. Commissioner of Wealth-tax [2002] 123 Taxman 494 (Delhi), Director of Income tax v. Alarippu (2000) 111 TAXMAN 511 (Delhi), Director of Income tax v. Acme Educational society (2010) 326 ITR 146 (Delhi), CIT v. Aloo Investment Co. Pvt. Ltd. [1979] 1 Taxman 433 (Bom.), and Third Income-tax Officer v. Jhaverbhai Patel Ch. Trust [1992] 43 ITD 195 (Bom.) it cannot be said that the assessee invested the amounts and committed violation within the meaning of section 13 (1) (d) of the Act. Further, whatever may be stage, the observations of the…

The DCIT (Exemptions) Circle-2, Ahmedabad vs. Shree Khodal Dham Trust, Kagwad, Rajkot

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

ITA 904/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad20 Apr 2022AY 2014-15

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedअपील सं./Ita No.904/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2014-2015 D.C.I.T.(Exemptions) Shree Khodal Dham Trust, Circle-2, Vs. Kagwad, Ahmedabad. Alka Society, 4Th Floor, Shri Sardar Patel Bhavan, Near Water Tank, Rajkot-360004. Pan: Aajts1017J

For Appellant: Shri Mehul Ranpura, A.RFor Respondent: Shri Vijaykumar Jaiswal, CIT.D.R
Section 11Section 12A

…ons have been relied upon. 1. Hon'ble High Court of Madhya Pradesh has in the case of CIT, Bhopal v. MaaVaishnav Education Society [2013] 38 taxmann.com 193 (Maclhya Pradesh) 2. Hon'ble High Court of Delhi in the case of DIT u. Acme Educational Society [2010] 326 ITR 146 (Delhi). 3. Hon'ble High Court of Allahabad in the case of CIT v. Kanpur Subhash ShikshaSamiti [2013] 36 taxmann.com 536 (Allahabad) 8.1 1 have perused the assessment order and the written submission filed by the AR of the appellant. It is seen from the assessment order that, \the AO has held that, the appellant trust has made investment in contr…

ACIT, Exemptions, Coimbatore vs. Mahendra Educational Trust, Manakkal

In the result, appeal filed by the Revenue is dismissed and cross objection filed by the assessee is allowed

ITA 125/CHNY/2019[2011-12]Status: DisposedITAT Chennai11 Feb 2021AY 2011-12

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 125 & 126/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co Nos.: 18 & 19/Chny/2019 (In Ita Nos.125 & 126/Chny/2019) िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri N.V. Balaji, Advocate राज" की ओर से /Revenue By : Shri G. Chandrababu, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 28.01.2021 घोषणा क" तार"ख/Date Of Pronouncement : 11.02.2021

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri G. Chandrababu, Addl.CIT
Section 1Section 11Section 12ASection 13Section 13(1)Section 13(1)(c)Section 13(1)(d)Section 13(2)(a)Section 13(2)(h)Section 13(3)

…n of object similar as available in its case, said amount could not be treated as investment or deposit constituting infringement of provision, of section 13(1)(d) of the Act. The Hon’ble Delhi High Court in the case of DIT v. Acme Educational Society, [2010] 326 ITR 146, had considered an identical issue and held that advancing of an interest- free temporary loan by one society to another society having similar objects, whose president was brother of president of assessee- society, would not amount to an ‘investment’ or a ‘deposit’ attracting section 13(1)(d) of the Act. The Hon’ble Delhi High Court, in yet anot…

ACIT, Exemptions, Coimbatore vs. Mahendra Educational Trust, Manakkal

In the result, appeal filed by the Revenue is dismissed and cross objection filed by the assessee is allowed

ITA 126/CHNY/2019[2012-13]Status: DisposedITAT Chennai11 Feb 2021AY 2012-13

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 125 & 126/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co Nos.: 18 & 19/Chny/2019 (In Ita Nos.125 & 126/Chny/2019) िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri N.V. Balaji, Advocate राज" की ओर से /Revenue By : Shri G. Chandrababu, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 28.01.2021 घोषणा क" तार"ख/Date Of Pronouncement : 11.02.2021

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri G. Chandrababu, Addl.CIT
Section 1Section 11Section 12ASection 13Section 13(1)Section 13(1)(c)Section 13(1)(d)Section 13(2)(a)Section 13(2)(h)Section 13(3)

…n of object similar as available in its case, said amount could not be treated as investment or deposit constituting infringement of provision, of section 13(1)(d) of the Act. The Hon’ble Delhi High Court in the case of DIT v. Acme Educational Society, [2010] 326 ITR 146, had considered an identical issue and held that advancing of an interest- free temporary loan by one society to another society having similar objects, whose president was brother of president of assessee- society, would not amount to an ‘investment’ or a ‘deposit’ attracting section 13(1)(d) of the Act. The Hon’ble Delhi High Court, in yet anot…

Dy.CIT(Exp), Bhubaneswar vs. M/S. Orissa Computer Academy, Bhubaneswar

In the result, appeals filed by the revenue and cross objections of the

ITA 427/CTK/2018[2010-11]Status: DisposedITAT Cuttack28 Jan 2021AY 2010-11

Bench: S/Shri P.M. Jagtap & C.M. Garg

For Appellant: Shri P.K.Mishra,, ARFor Respondent: Shri M.K.Gautam CIT DR
Section 11Section 12ASection 13Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH, CUTTACK BEFORE S/SHRI P.M. JAGTAP, VICE PRESIDENT AND C.M. GARG, JUDICIAL MEMBER ITA Nos.427 to 429/CTK/2018 Assessment Years : 2010-11, 2013-14 & 2014-15 DCIT (Exemptions), Vs. M/s. Orissa Computer Bhubaneswar. Academy, Prasanti Vihar, Pubasasana, Kausalya Ganga, Bhubaneswar. PAN/GIR No.AAAAO 0070 D (Appellant) .. ( Respondent) C.O.Nos.13, 14 & 15/CTK/2020 (in ITA Nos.427 to 429/CTK/2018) Assessment Years : 2010-11, 2013-14 & 2014-15 M/s. Orissa Computer Academy, Vs. DCIT (Exemptions), Prasanti Vihar, Pubasasana, Bhubaneswar. Kausalya Ganga, Bhubaneswar P…

ACIT(E)- Circle- 1(1), New Delhi vs. Indian Broadcasting Foundation, New Delhi

In the result, appeals of the Revenue are dismissed

ITA 4194/DEL/2017[2014-15]Status: DisposedITAT Delhi14 Sept 2020AY 2014-15
Section 11Section 11(1)Section 12ASection 13(1)(d)Section 143(3)Section 25Section 8

…ublic Charitable Trust [2001] 250 ITR 475 (Delhi), Anand Charitable Trust v. Commissioner of Wealth-tax [2002] 123 Taxman 494 (Delhi), Director of Income tax v. Alarippu (2000) 111 TAXMAN 511 (Delhi), Director of Income tax v. Acme Educational society (2010) 326 ITR 146 (Delhi), CIT v. Aloo Investment Co. Pvt. Ltd. [1979] 1 Taxman 433 (Bom.), and Third Income-tax Officer v. Jhaverbhai Patel Ch. Trust [1992] 43 ITD 195 (Bom.) he argued that in order to conclude that the deposits made by the assessee in BARC is in the nature of investment, regard must be had to the element of intention to earn any profits without…

ACIT(E)- Circle- 1(1), New Delhi vs. Indian Broadcasting Foundation, New Delhi

In the result, appeals of the Revenue are dismissed

ITA 4193/DEL/2017[2013-14]Status: DisposedITAT Delhi14 Sept 2020AY 2013-14
Section 11Section 11(1)Section 12ASection 13(1)(d)Section 143(3)Section 25Section 8

…ublic Charitable Trust [2001] 250 ITR 475 (Delhi), Anand Charitable Trust v. Commissioner of Wealth-tax [2002] 123 Taxman 494 (Delhi), Director of Income tax v. Alarippu (2000) 111 TAXMAN 511 (Delhi), Director of Income tax v. Acme Educational society (2010) 326 ITR 146 (Delhi), CIT v. Aloo Investment Co. Pvt. Ltd. [1979] 1 Taxman 433 (Bom.), and Third Income-tax Officer v. Jhaverbhai Patel Ch. Trust [1992] 43 ITD 195 (Bom.) he argued that in order to conclude that the deposits made by the assessee in BARC is in the nature of investment, regard must be had to the element of intention to earn any profits without…

ITO(Exmp), WD -2(1), Durgapur vs. M/S Gurukul Education Institute, Durgapur

Appeal is dismissed

ITA 1369/KOL/2016[2010-11]Status: DisposedITAT Kolkata14 Feb 2020AY 2010-11

Bench: Shri P.M. Jagtap, V.P & Shri S. S. Godara, Jm आयकर अपीलसं./I.T.A No.1369/Kol/2016 ("नधा"रण वष" / Assessment Year: 2010-11) Ito (Exemptions), Ward-2(1), Vs. M/S. Gurukul Educational Institute Durgapur G.T. Road, Rajbandh, Durgapur-713212. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaatg7615B (Appellant) .. (Respondent) Appellant By : Smt. Ranu Biswas, Sr. Dr Respondent By : Shri Anikesh Banerjee & Shri Anupam Kr. Dey, Advocate सुनवाई क" तार"ख/ Date Of Hearing : 09/12/2019 घोषणा क" तार"ख/Date Of Pronouncement : 14/02/2020 आदेश / O R D E R Per Shri S. S. Godara: This Revenue’S Appeal For Assessment Year 2010-11 Arises Against The Commissioner Of Income Tax (A)-Durgapur’S Order Dated 28.03.2016 Passed In Case No.90/Cit(A)/Dgp/2013-14 Involving Proceedings U/S 143(3) Of The Income Tax Act, 1961; In Short ‘The Act’. Heard Both The Parties. Case File Perused.

For Appellant: Smt. Ranu Biswas, Sr. DRFor Respondent: Shri Anikesh Banerjee, & Shri Anupam Kr. Dey, Advocate
Section 11Section 13Section 13(1)(c)Section 143(3)Section 250(4)Section 40A(2)

…f the Act. Without going deeper in merits of the issue, we notice at the outset that the assessee’s recipient itself carries out educational activities only. Hon’ble Delhi High Court’s judgment in Director of IT (Exemption) vs. Acme Educational Society (2010) 326 ITR 146 (Del) holds that such an interest free loan given to an educational society enjoying section 12AA registration having similar objects cannot be disallowed u/s 11(5) r.w. section 13(1)(d) of the Act. The CIT(A) has gone by the very reasoning whilst deleting the impugned disallowance. We therefore decline the Revenue’s latter substantive grievance…

DCIT, C-1 (Exemptions), Chandigarh vs. M/S Shiva Educational Trust, Moga

In the result all the above appeals filed by the Revenue

ITA 1314/CHANDI/2017[2014-15]Status: DisposedITAT Chandigarh26 Jul 2018AY 2014-15

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

For Appellant: S/Shri Jagjeevan Kumar Garg, CIT DRFor Respondent: Shri P.N. Arora, Adv
Section 11Section 12ASection 13Section 13(3)

…said to have violated the provisions of section 13(l)(d) r.w.s 11(5) of the Act. The reliance placed by Ld. counsel for the assessee on the decision of the Hon'ble Delhi High Court in the case of Director of Income Tax (Exemption) vs ACME Educational Society 326 ITR 146 is apt, wherein after discussing the issue at length it was held that interest free loan given by one charitable society to another charitable society having similar objects was neither a deposit or investment in violation of section 13(l)(d) r.w.s. 11(5) of the Act. The relevant findings of the Hon'ble High Court at para 15 of its order are as u…

DCIT, C-1 (Exemptions), Chandigarh vs. Ace Educational & Charitable Society, Moga

In the result all the above appeals filed by the Revenue

ITA 1311/CHANDI/2017[2014-15]Status: DisposedITAT Chandigarh26 Jul 2018AY 2014-15

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

For Appellant: S/Shri Jagjeevan Kumar Garg, CIT DRFor Respondent: Shri P.N. Arora, Adv
Section 11Section 12ASection 13Section 13(3)

…said to have violated the provisions of section 13(l)(d) r.w.s 11(5) of the Act. The reliance placed by Ld. counsel for the assessee on the decision of the Hon'ble Delhi High Court in the case of Director of Income Tax (Exemption) vs ACME Educational Society 326 ITR 146 is apt, wherein after discussing the issue at length it was held that interest free loan given by one charitable society to another charitable society having similar objects was neither a deposit or investment in violation of section 13(l)(d) r.w.s. 11(5) of the Act. The relevant findings of the Hon'ble High Court at para 15 of its order are as u…

DCIT, Chandigarh vs. M/S Shri Guru Gobind Singh Foundation, Moga

In the result all the above appeals filed by the Revenue

ITA 1230/CHANDI/2016[2013-14]Status: DisposedITAT Chandigarh26 Jul 2018AY 2013-14

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

For Appellant: S/Shri Jagjeevan Kumar Garg, CIT DRFor Respondent: Shri P.N. Arora, Adv
Section 11Section 12ASection 13Section 13(3)

…said to have violated the provisions of section 13(l)(d) r.w.s 11(5) of the Act. The reliance placed by Ld. counsel for the assessee on the decision of the Hon'ble Delhi High Court in the case of Director of Income Tax (Exemption) vs ACME Educational Society 326 ITR 146 is apt, wherein after discussing the issue at length it was held that interest free loan given by one charitable society to another charitable society having similar objects was neither a deposit or investment in violation of section 13(l)(d) r.w.s. 11(5) of the Act. The relevant findings of the Hon'ble High Court at para 15 of its order are as u…

DCIT, Chandigarh vs. M/S Shiva Educational Trust, Moga

In the result all the above appeals filed by the Revenue

ITA 1229/CHANDI/2016[2013-14]Status: DisposedITAT Chandigarh26 Jul 2018AY 2013-14

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

For Appellant: S/Shri Jagjeevan Kumar Garg, CIT DRFor Respondent: Shri P.N. Arora, Adv
Section 11Section 12ASection 13Section 13(3)

…said to have violated the provisions of section 13(l)(d) r.w.s 11(5) of the Act. The reliance placed by Ld. counsel for the assessee on the decision of the Hon'ble Delhi High Court in the case of Director of Income Tax (Exemption) vs ACME Educational Society 326 ITR 146 is apt, wherein after discussing the issue at length it was held that interest free loan given by one charitable society to another charitable society having similar objects was neither a deposit or investment in violation of section 13(l)(d) r.w.s. 11(5) of the Act. The relevant findings of the Hon'ble High Court at para 15 of its order are as u…

DCIT, Chandigarh vs. Ace Educational & Charitable Society, Moga

In the result all the above appeals filed by the Revenue

ITA 1228/CHANDI/2016[2013-14]Status: DisposedITAT Chandigarh26 Jul 2018AY 2013-14

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

For Appellant: S/Shri Jagjeevan Kumar Garg, CIT DRFor Respondent: Shri P.N. Arora, Adv
Section 11Section 12ASection 13Section 13(3)

…said to have violated the provisions of section 13(l)(d) r.w.s 11(5) of the Act. The reliance placed by Ld. counsel for the assessee on the decision of the Hon'ble Delhi High Court in the case of Director of Income Tax (Exemption) vs ACME Educational Society 326 ITR 146 is apt, wherein after discussing the issue at length it was held that interest free loan given by one charitable society to another charitable society having similar objects was neither a deposit or investment in violation of section 13(l)(d) r.w.s. 11(5) of the Act. The relevant findings of the Hon'ble High Court at para 15 of its order are as u…

Director of Income Tax (Exemption) v. ACME Educational Society (326 ITR 146) — Cited in 32 Judgments | BharatTax