How many judgments cite Lissie Medical Institutions v. CIT?

164 judgments on BharatTax cite Lissie Medical Institutions v. CIT (348 ITR 344), spanning 2013 to 2025.

Lissie Medical Institutions v. CIT

Q: Which sections of the Income Tax Act does Lissie Medical Institutions v. CIT come up under?

It is most often cited in judgments turning on Section 11 to 13 of the Income Tax Act, Section 11(6) of the Income Tax Act, Section 271(1)(c) r.w.s.274 of the Act, Section 28 of the Income Tax Act, Section 139(1), Section 139(5).

348 ITR 344High Court2012#596 most cited

What is Lissie Medical Institutions v. CIT authority for?

The Kerala High Court held that charitable institutions claiming exemption under Section 11 are not entitled to claim depreciation on assets used for charitable purposes, taking a view contrary to most other High Courts.

164

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2013 to 2025.

Also referred to as

Lissie Medical Institutions v CIT · Section 11 Income Tax Act · depreciation charitable trust · charitable institution depreciation · Section 11(6) amendment · carry forward depreciation · accumulation of income · application of income · Kerala High Court depreciation

Also reported as

24 Taxmann.com 9209 Taxmann 19

Sections most often in play

Section 11 to 13 of the Income Tax Act Section 11(6) of the Income Tax Act Section 271(1)(c) r.w.s.274 of the Act Section 28 of the Income Tax Act Section 139(1)Section 139(5)Section 143(3)Section 17

Read the full judgment

Issues it is cited on

section 11(6)section 10(23c)(iv)accumulation of income section 11(1)(a)proviso to section 2(15)section 11(1)section 251(2)section 10(23c)section 2(15)application of income section 32 section 28

Judgments citing Lissie Medical Institutions v. CIT

M/S Rams Education Foundation, Bangalore vs. Income Tax Officer Ward-2 (Exemption), Bangalore

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

ITA 1381/BANG/2017[2012-13]Status: DisposedITAT Bangalore23 Mar 2018AY 2012-13

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raoassessment Year : 2012-13

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT

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

…ouble deduction when already full expenditure has been allowed in earlier years. ITA Nos.1381 & 1464/Bang/2017 Page 8 of 14 3. The CIT(A) has failed to appreciate the fact that the Hon'ble Kerala High Court in the case of Lissie Medical Intuitions Vs. CIT (348 ITR 344) has held that depreciation cannot be allowed on assets, where cost of such assets has already been allowed as application of income in the year of acquisition/ purchase of asset. 4. The CIT(A) has failed to appreciate that the Hon'ble Supreme Court in the case of Escorts Ltd. & another Vs. Union of India (199 ITR 43), while dealing with the issu…

Deputy Commissioner of Income Tax (E) Circle-1, Bangalore vs. M/S Vidyanidhi Education Trust, Bangalore

In the result, appeal of the Revenue is dismissed

ITA 1484/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Feb 2018AY 2012-13

Bench: Shri. Jason P. Boaz

For Appellant: Shri. S. V. Ravishankar, AdvocateFor Respondent: Shri. B. R Ramesh, Addl. CIT

Section 11Section 11(1)

…ITA.1484/Bang/2017 Page - 1 IN THE INCOME TAX APPELLATE TRIBUNAL BENGALURU BENCH 'A', BENGALURU BEFORE SHRI. JASON P. BOAZ, ACCOUNTANT MEMBER AND SHRI. LALIET KUMAR, JUDICIAL MEMBER I.T.A No.1484/Bang/2017 (Assessment Year : 2012-13) Deputy Commissioner of Income-tax (Exemptions), Circle -1, Bengaluru .. Appellant v. M/s. Vidyanidhi Education Trust, No.42/3, Shivanahalli, Yelahanka Hobli, Bengaluru 560 064 .. Respondent PAN : AAATV0825G Assessee by : Shri. S. V. Ravishankar, Advocate Revenue by : Shri. B. R Ramesh, Addl. CIT Heard on : 05.02.2018 Pronounced on : 28 .02.2018 O R D E R PER LALIET KUMAR, J…

The Dy.DIT (Exemption), Ahmedabad vs. Shree Monark Education Trust, Ahmedabad

In the result, the appeal is dismissed

ITA 373/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad30 Jan 2018AY 2012-13

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

…same. 3. It may be mentioned that most of the High Courts have taken the aforesaid view with only exception thereto by the High Court of Kerala which has taken a contrary view in 'Lissie Medical Institutions v. CIT [2012] 24 taxmann.com 9/209 Taxman 19 (Mag.)/348 ITR 344 (Ker.)'. 4. It may also be mentioned at this stage that the legislature, realising that there was no specific provision in this behalf in the Income Tax Act, has made amendment in Section 11(6) of the Act vide Finance Act No. 2/2014 which became effective from the Assessment Year 2015-2016. The Delhi High Court has taken the view and rightly so,…

The Assistant Commissioner of Income Tax (Exemption0 Circle- 1, Mangalore vs. M/S Anjuman E Islams, Hubli

In the result, appeals of the Revenue are dismissed

ITA 1702/BANG/2017[2011-12]Status: DisposedITAT Bangalore22 Dec 2017AY 2011-12

Bench: Shri Sunil Kumar Yadav

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Kumar Ajith, Additional CIT

Section 10(2)Section 11Section 15Section 35Section 35(1)(iv)Section 70

…in allowing depreciation which amounts to double deduction when already full expenditure has been allowed in earlier years. 3. The CIT(A) has failed to appreciate the fact that the Hon'ble Kerala High Court in the case of I,issie Medical intuitions Vs. CIT (348 ITR 344) has held that depreciation cannot be allowed on assets, where cost of such assets has already been allowed as application of income in the year of acquisition/ purchase of asset. 4. The CIT(A) has failed to appreciate that the Hon'ble Supreme Court in the case of Escorts Ltd. & another Vs. Union of India (199 ITR 43), while dealing with the issu…

The Jt. DIT ( Exemption), Ahmedabad vs. Nirma University, Ahmedabad

Appeal is dismissed

ITA 1627/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad29 Nov 2017AY 2011-12

For Appellant: H. C. Shah, A.RFor Respondent: Aditya Shukla, D.R

Section 12ASection 143(3)

…uction i.e. both towards capital expenditure as well as whilst computing income of the relevant previous year. He therefore quoted hon’ble apex court’s decision hereinabove as well as hon’ble Kerala high court’s decision in Lissie Medical Institutions vs. CIT 348 ITR 344 (Kerla) to conclude that the depreciation claim in question would not be admissible to assessee. All this reasoning resulted in the impugned disallowance of Rs.5,77,27,323/- being made in assessee’s hands in assessment order dated 18.03.2014. 3. The CIT(A) reverses Assessing Officer’s action as under: “3.2 I have carefully considered the above s…

Income Tax Officer(Exemptions), Bangalore vs. Shradda Trust, Bangalore

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

ITA 1810/BANG/2016[2012-13]Status: DisposedITAT Bangalore10 Nov 2017AY 2012-13

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodiaassessment Year :2012-13

For Appellant: NoneFor Respondent: Smt. Padmameenakshi, JCIT (DR)

Section 10(2)Section 11Section 11(1)Section 11(1)(a)Section 11(2)Section 11(3)Section 35Section 35(1)(iv)

…d 30.08.2016 for Assessment Year 2012-13. 2. The grounds raised by the revenue are as under. “Disallowance of depreciation: (i). The CIT(A) has failed to appreciate the fact that the Hon'ble Kerala High Court in the case of Lissie Medical Intuitions Vs. CIT (348 ITR 344) has held that depreciation cannot be allowed on assets, where cost of such assets has already been allowed as application of income in the year of acquisition/ purchase of asset. (ii). The CIT(A) has failed to appreciate that the Hon'ble Supreme Court in the case of Escorts Ltd. & another Vs. Union of India (199 ITR 43), while dealing with the i…

Assistant Commissioner of Income Tax (Exemption) Circle-1, Mangalore vs. M/S Shri Siddarameshwar Education Trust, Bangalore

In the result, the appeal by the Revenue is dismissed

ITA 550/BANG/2017[2010-11]Status: DisposedITAT Bangalore13 Oct 2017AY 2010-11

For Appellant: Smt. Padma Meenakshi, JCIT (D.R)For Respondent: None

Section 11(1)Section 143(3)Section 32Section 35(2)(iv)

…eady been recovered by way of exemption as application of income amounts to double deduction and double benefit on the same asset. The AO referred to the decision of the of Hon'ble High Court of Kerala in the case of DDIT(E) v. 3 Lissie Medical Institutions, 348 ITR 344 (Ker) wherein it was held that allowing depreciation of a depreciable asset when the cost of acquisition of depreciable asset was allowed as application of income for charitable purpose amounts to double depreciation and therefore depreciation cannot be allowed. The AO also distinguished the cases cited by the Assessee. 5. On appeal by the Asses…

Assistant Commissioner of Income-Tax, Bangalore vs. M/S.Gokula Education Foundation (Medical), Bangalore

In the result, the appeals by the Revenue are dismissed

ITA 1655/BANG/2016[2008-09]Status: DisposedITAT Bangalore13 Oct 2017AY 2008-09

For Appellant: Ms. Neera Malhotra, CIT (D.R)For Respondent: Shri Narendra Sharma, Advocate

Section 11(1)Section 143(3)Section 263Section 32Section 35(2)(iv)

…ders u/s.263 of the Act in the case of the two Assessees both dated 29.2.2012 directing the AO to disallow claim for depreciation. The CIT also referred to the decision of the Hon'ble High Court of Kerala in the case of DDIT(E) v. Lissie Medical Institutions, 348 ITR 344 (Ker) wherein it was held that allowing depreciation of a depreciable asset when the cost of acquisition of depreciable asset was allowed as application of income for charitable purpose amounts to double depreciation and therefore depreciation cannot be allowed. 5. Pursuant to the order of the CIT u/s.263 of the Act dated 29.2.2012, the AO’s in…

ITO-(Exemptions)-Ward-3, Bangalore vs. M/S. Sri Keshava Trust, Bangalore

In the result, appeal of the Revenue is dismissed

ITA 1510/BANG/2016[2007-08]Status: DisposedITAT Bangalore10 Oct 2017AY 2007-08

Bench: Shri Sunil Kumar Yadav & Shri A. K. Garodiaassessment Year : 2007-08

For Appellant: NoneFor Respondent: Shri. Chandrashekar, ACIT

Section 11Section 11(1)

…s preferred by the assessee against the order of CIT(A), inter alia, on the following grounds: “Disallowance of depreciation: (i) The CIT(A) has failed to appreciate the fact that the Hon'ble Kerala High Court in the case of Lissie Medical Intuitions Vs. CIT (348 ITR 344) has held that depreciation cannot be allowed on assets, where cost of such assets has already been allowed as application of income in the year of acquisition/ purchase of asset. (ii) Though the Finance Act, 2014 has amended the Income Tax Act, 1961 with regard to non-allowance of depreciation to charitable/ religious trust Page 2 of 5 or inst…

Karl Kubel Foundation for Child and Family, Kochi vs. ACIT

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 868/CHNY/2017[2010-11]Status: DisposedITAT Chennai05 Oct 2017AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.867 & 868/Mds/2017 "नधा"रण वष" / Assessment Year : 2009-10 & 2010-11 M/S Karl Kubel Foundation For The Assistant Commissioner Of Child & Family, V. Income Tax (Exemption), 39/741, Iyattil Road, Iyattu Jn., Coimbatore. Kochi – 682 011. Pan : Aaatk 2501 N (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri P.M. Veeramani, CAFor Respondent: Shri AR.V. Sreenivasan, JCIT

Section 11Section 12ASection 25

…आयकर अपील"य अ"धकरण, ‘ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी एन.आर.एस. गणेशन, "या"यक सद"य एवं "ी एस जयरामन, लेखा सद"य केसम" BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER AND SHRI S. JAYARAMAN, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.867 & 868/Mds/2017 "नधा"रण वष" / Assessment Year : 2009-10 & 2010-11 M/s Karl Kubel Foundation for The Assistant Commissioner of Child and Family, v. Income Tax (Exemption), 39/741, Iyattil Road, Iyattu Jn., Coimbatore. Kochi – 682 011. PAN : AAATK 2501 N (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri P.M. Veeramani,…

Karl Kubel Foundation for Child and Family, Kochi vs. ACIT

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 867/CHNY/2017[2009-10]Status: DisposedITAT Chennai05 Oct 2017AY 2009-10

For Appellant: Shri P.M. Veeramani, CAFor Respondent: Shri AR.V. Sreenivasan, JCIT

Section 11Section 12ASection 25

DCIT, Bangalore vs. M/S B S & G Foundation, Bangalore

In the result, Revenue’s appeal for asst

ITA 884/BANG/2016[2011-12]Status: DisposedITAT Bangalore04 Oct 2017AY 2011-12

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazthe Dy. Commissioner Of Income-Tax (Exemptions), Bengaluru. . Appellant Vs. M/S B S & G Foundation, 502, 2Nd Floor, 5Th ‘C’ Main, 5Th Cross, 2Nd Block, Hrbr Layout, Kalyannagar, Bangalore. . Respondent Pan – Aaatb6131D. Appellant By : Smt. Padmameenakshhi, Jcit Respondent By : Shri R.T Balasubramanyam, C.A Date Of Hearing : 28-9-2017 Date Of Pronouncement : 4-10-2017 O R D E R

For Appellant: Smt. Padmameenakshhi, JCITFor Respondent: Shri R.T Balasubramanyam, C.A

Section 11Section 11(1)(a)Section 11(2)Section 11(3)Section 11(5)Section 12ASection 13Section 143(3)

…income will be recognized on the basis of net surplus/book profits rather than gross receipts. Disallowance of depreciation: (i). The CIT(A) has failed to appreciate the fact that the Hon'ble Kerala High Court in the case of Lissie Medical Intuitions Vs. CIT (348 ITR 344) has held that depreciation cannot be allowed on assets, where cost ITA No.884/B/16 5 of such assets has already been allowed as application of income in the year of acquisition/ purchase of asset. (ii). The CIT(A) has failed to appreciate that the Hon'ble Supreme Court in the case of Escorts Ltd. & another Vs. Union of India (199 ITR 43), wh…

The Assistant Commissioner of Income Tax (E) Circle-1, Bangalore vs. M/S Green Wood High School, Bangalore

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

ITA 749/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Sept 2017AY 2012-13

Bench: Shri Arun Kumar Garodia & Shri Vijay Pal Raoassessment Year : 2012-13

For Appellant: NoneFor Respondent: Shri B.R. Ramesh, JCIT (DR)

Section 10(2)Section 11Section 11(1)Section 11(1)(a)Section 15Section 35Section 35(1)Section 35(1)(iv)

…29.12.2016 for Assessment Year 2012-13. 2. The grounds raised by the revenue are as under. “On Disallowance of depreciation: (i) The CIT(A) has failed to appreciate the fact that the Hon'ble Kerala High Court in the case of Lissie Medical Intuitions Vs. CIT (348 ITR 344) has held that depreciation cannot be allowed on assets, where cost of such assets has already been allowed as application of income in the year of acquisition/ purchase of asset. (ii) The CIT(A) has failed to appreciate that the Hon'ble Supreme Court in the case of Escorts Ltd. & another Vs. Union of India (199 ITR 43), while dealing with the is…

Asst. Commissioner of Income-Tax, Bangalore vs. M/S. the New Cambridge Educational Trust, Bangalore

In the result, both the appeals of revenue are dismissed

ITA 1388/BANG/2016[2009-10]Status: DisposedITAT Bangalore20 Sept 2017AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri Pramod Singh, CIT (D.R)For Respondent: Shri P.R. Suresh, CA

Section 28

…i Lakshmi Ammani College Trust in ITA Nos.391 & 392/Bang/2016. The learned Departmental Representative has relied upon the order of the Assessing Officer as well as the decision of Hon'ble Karnataka High Court in the case of Lisse Medical Institutions Vs. CIT 348 ITR 344 as well as the decision of Hon'ble Supreme Court in the case of Escorts Limited & Another Vs. Union of India 199 ITR 43 (SC). At the outset, we note that the co-ordinate bench of this Tribunal nthe case of DCIT (Exemptions) Vs. M/s. Maharani Lakshmi Ammani College Trust (supra) has considered and decided this issue in paras 7 & 8 as under : “ 7.…

ADIT (E), New Delhi vs. Fortune Society for Development and Promotion of International Business, New Delhi

In the result ground No. 2

ITA 2698/DEL/2012[2007-08]Status: DisposedITAT Delhi18 Sept 2017AY 2007-08

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiadit(E), Vs. Fortune Society For Tc-Ii, New Delhi Development & Promotion Of International Business, G-4, Community Centre, Naraina Vihar, New Delhi Pan:Aaatf0849L (Appellant) (Respondent)

For Appellant: Shri Anshu Prakash, Sr. DRFor Respondent: Shri Satish Khosla, Adv

Section 11Section 11(1)Section 12Section 143Section 2

…of the exemption u/s. 11(1)." 4. Accordingly, the appeal was dismissed after observing that no contrary judgment has been brought to the notice of this Court. 5. The High Court of Kerala in Lissie Medical Institutions versus Commissioner of Income Tax, (2012) 348 ITR 344 (Ker) has taken a different view, inter alia, holding as under: "5. It is settled position through several decisions of High Courts and Supreme Courts that when business is held in trust by charitable institutions income from business has to be computed by Page 5 of 18 granting deductions provided u/s 30 to 43D as provided under S.29 of the Incom…

Assistant Commissioner of Income-Tax, Bangalore vs. M/S.Karnataka State Cricket Association, Bangalore

In the result, Revenue’s appeal for asst

ITA 1615/BANG/2016[2006-07]Status: DisposedITAT Bangalore01 Jun 2017AY 2006-07

Bench: Shri Vijaypal Rao & Shri Jason P Boazthe Asst. Commissioner Of Income-Tax, (E), Circle – 1, Bangalore. . Appellant Vs. M/S Karnataka State Cricket Association, Chinnaswamy Stadium, Mg Road, Bangalore. . Respondent

For Appellant: Smt. Swapna Das, JCITFor Respondent: Shri Narendra Sharma, Advocate

Section 143(3)

…ompleted u/s 143(3) of the Income-tax Act, 1961 (in short ‘the Act’) vide order dated 19/12/2008, disallowing the depreciation claimed by the assessee by following the decision of the Hon’ble Kerala High Court in the case of Lissie Medical Institutions (2012) 348 ITR 344 (Ker). 2.2 Aggrieved by the order of assessment dated 19/12/2008 for asst. year 2006-07, the assessee preferred an appeal before the CIT(A)-14, Bangalore challenging the AO’s action in disallowing the assessee’s claim for depreciation. The ld CIT(A) vide the impugned order dated 30/6/2016 allowed the assessee’s appeal following, inter alia, the d…

DCIT, Chennai vs. M/S. Tamil Nadu Cricket Association, Chennai

In the result, both the appeals of the Revenue as well as the cross-objections of the assessee are dismissed

ITA 2557/CHNY/2016[2012-13]Status: DisposedITAT Chennai31 May 2017AY 2012-13

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita Nos.2556 & 2557/Mds/2016 & C.O. Nos.158 & 159/Mds/2016 (In Ita Nos.2556 & 2557/Mds/2016) "नधा"रण वष" / Assessment Years : 2011-12 & 2012-13

For Appellant: Dr. Milind Madhukar Bhusari, CITFor Respondent: Shri V. Ravichandran, CA

Section 11Section 12ASection 2(15)

…आयकर अपील"य अ"धकरण, ‘बी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी एन.आर.एस. गणेशन, "या"यक सद"य एवं "ी "ड.एस. सु"दर "संह, लेखा सद"य केसम" BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER AND SHRI D.S. SUNDER SINGH, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.2556 & 2557/Mds/2016 & C.O. Nos.158 & 159/Mds/2016 (in ITA Nos.2556 & 2557/Mds/2016) "नधा"रण वष" / Assessment Years : 2011-12 & 2012-13 The Deputy Commissioner of M/s Tamil Nadu Cricket Income Tax (Exemptions), v. Association, Chennai Circle, No.5, M.A. Chidambaram Stadium, Chennai - 600 034. Hostel Road, Chepauk, Chennai - 600 005.…

DCIT, Chennai vs. M/S. Tamil Nadu Cricket Association, Chennai

In the result, both the appeals of the Revenue as well as the cross-objections of the assessee are dismissed

ITA 2556/CHNY/2016[2011-12]Status: DisposedITAT Chennai31 May 2017AY 2011-12

For Appellant: Dr. Milind Madhukar Bhusari, CITFor Respondent: Shri V. Ravichandran, CA

Section 11Section 12ASection 2(15)

Dy.Director of Income Tax, Ahmedabad vs. Monark Education Trust, Ahmedabad

In the result, the appeal is dismissed

ITA 3088/AHD/2014[2011-12]Status: DisposedITAT Ahmedabad24 May 2017AY 2011-12

Section 143(3)Section 28Section 32

…f income as this would amount to double deduction in view of the decision of the Hon’ble Supreme Court in the case of Escorts Ltd., 199 ITR 43, the decision of Kerala High Court in the case of Lissie Medical Institutions vs. Commissioner of Income Tax, Kochi, 348 ITR 344 and decision of Delhi Assessment Year: 2011-12 Page 2 of 9 High Court in the case of DIT(E) vs. Charanjiv Charitable Trust in (2014) 43 taxmann.com 300 (Delhi). (II) Whether, on the facts and in the circumstances of the case, deduction of depreciation u/s.32 which falls under the head “Profit and Gains from business and profession’ of the Income…

The Christia Literature Society, Chennai vs. JCIT (OSD), Chennai

In the result, I set aside the orders of the lower authorities

ITA 2818/CHNY/2016[2009-10]Status: DisposedITAT Chennai21 Apr 2017AY 2009-10

Bench: Shri Abraham P. George]

For Appellant: Smt. B. Jaisheila, C.AFor Respondent: Shri. B. Sahadevan, IRS, JCIT

Section 11

…ntrol. 24. Coming to the aspect of claim of depreciation, what I find is that there are judgments of various High Court in favour of the assessee as well as against assessee. Hon’ble Kerala High Court in the case of Lissie Medical Institutions vs. CIT (2012) 348 ITR 344 as well as Hon’ble Delhi High Court in the case of Charanjiv Charitable Trust (supra) had taken a view claim of depreciation on assets, value of which was allowed as application of income could not be allowed. As against this Hon’ble High Courts of Madhya Pradesh, Karnakata, Punjab & Haryana and Bombay in CIT vs. Raipur Pallattine Society 180…