Pushpavati Singhania Resaerch Institute for Lever, Renal and Digestive Diseases v. DDIT(E), New Delhi

29 SOT 316Income Tax Appellate Tribunal2009#4234 most cited

What is Pushpavati Singhania Resaerch Institute for Lever, Renal and Digestive Diseases v. DDIT(E), New Delhi authority for?

Carry forward of excess application of funds by a charitable trust to a subsequent year is not permissible in law. Such notional application of income is not allowed.

28

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2023.

Also referred to as

Pushpawati Singhania Research Institute · DDIT(E) · carry forward of excess application of funds · charitable trust · exemption u/s 11(2) · notional application of income

Judgments citing Pushpavati Singhania Resaerch Institute for Lever, Renal and Digestive Diseases v. DDIT(E), New Delhi

M/S SINDHI YOUTH ASSOCIATION,BANGALORE vs. ASSISTANT DIRECTOR OF INCOME TAX (EXEMPTIONS), CIRCLE-17(2), BANGALORE

ITA 358/BANG/2023[2008-09]Status: DisposedITAT Bangalore07 Aug 2023AY 2008-09

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2008-09

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Shri Veera Raghavan, Jt.CIT(DR)(ITAT)
Section 11Section 11(1)(a)Section 12ASection 70

…applied in earlier assessment year will also not qualify for exemption. The CIT(A) also relied on the decisions of ITO v. Trustees of Sri Satya Sai Trust (33 ITD 320) and Pushpavati Singhania Research Institute for Liver, Rengal & Digestive Diseases v. DDIT, 29 SOT 316 (Del Trib). However, the CIT(Appeals) considered the decisions of the ITAT Bangalore in the case of M/s. Jyothy Charitable Trust in ITA No.662/Bang/2015 and Academy of Liberal Education in ITA No.687/Bang/2014 dated 20.2.2015 in favour of the assessee and therefore allowed the appeal of the assessee on this issue. 7. Against the order of the CIT(…

JCIT(OSD), (EXEMPTIONS), CHENNAI vs. MUTHAYAMMAL EDUCATIONAL TRUST, CHENNAI

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

ITA 294/CHNY/2018[2009-10]Status: DisposedITAT Chennai27 Oct 2021AY 2009-10

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकरअपीलसं./Ita No.294/Chny/2018 िनधा"रणवष"/Assessment Year: 2009-10

For Appellant: Mrs. R. Anita, Addl. CITFor Respondent: Mr. I. Dinesh, Advocate
Section 11Section 143(3)

…losses of earlier year and set-offsuch losses against the income of the current year. 2.4 The Id. CIT(A) failed to consider the decision of ITAT, Delhi in the case of PushpawatiSinghania Research Institute for Liver, Renal & Digestive Diseases vs Dy.DIT (2009)29 SOT 316, ITAT, Chennai decisions in the case of Anjuman-E-Himayath- lslamvs.ADIT(Exemption) - IV, Chennai for the A.Y. 2009-10 reported in [2015] 59 taxmann.com 379 and M/s Inter Church Service Association in ITA NO.1253/Mds/2014 dated 05/02/2016. 2.7 The Id.CIT(A) failed to observe that carry forward of excess application of funds would result in notiona…

DCIT (EXEMPTION), NEW DELHI vs. OM PRAKASH JINDAL GRAMIN JAN KALYAN SANSTHAN, NEW DELHI

The appeal of the revenue is dismissed

ITA 6012/DEL/2015[2011-12]Status: DisposedITAT Delhi03 Sept 2019AY 2011-12

Bench: Shri Suchitra Kamble & Shri Prashant Maharishi, [Assessment Year: 2011-12] Dcit(E), Om Prakash Jindal Gramin Jan Circle-2(1), Room No.2408, Kalyan Sansthan, 24Th Floor, E-2 Block, 06, Prithvi Raj Road, Pratyaksh Kar Bhavan, New Delhi-110001 Dr. S.P. Mukherjee Civic Centre, New Delhi-11002

Section 11Section 12ASection 72Section 80G

…n directing the Assessing Officer to allow benefit of carry forward of deficit loss of Rs.25,66,47,941/- in view of the decision of Delhi Tribunal in the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases Vs. DDIT (E) (2009) 29 SOT 316 (Del.). 6. The Ld. AR relied upon the order of the CIT(A). 7. We have heard both the parties and perused all the relevant material available on record. The CIT(A) held as under : “4.5 The AO has added the sum of Rs. 19 crore in the income of the Appellant on the premises that the transfer from the corpus Fund to General Reserve tantamount incom…

DCIT (EXEMPTIONS), CIRCLE-2,, AHMEDABAD vs. PADMA EDUCATION & WELFARE SOCIETY,, GANDHIDHAM

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

ITA 665/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad06 Aug 2019AY 2014-15

Bench: Shri Waseem Ahmed & Ms Madhumita Royअपील सं./Ita No.665/Ahd/2018 &"नधा"रण वष"/Asstt. Year:2014-2015

For Appellant: NoneFor Respondent: Shri Mudit Nagpal, Sr.D.R
Section 11Section 143(3)

…oss of earlier years and set-off such losses against income of the current year. This is held by the Hon'ble Delhi ITAT in case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases vs. Deputy Director of Income-tax (Exemption) 2009 29 SOT 316 (Delhi). It was held that when income accumulated in earlier year cannot qualify for exemption under section 11 (2). the excess income applied in earlier assessment year would also not qualify for exemption. Reliance also placed in the case of Bhartiya Vidya Mandir v/s. The Income-tax Officer. Ward Vl(l),, Ludhiana ITA No. 1093/Chd/2013 (A. Y.2010…

DCIT (EXEMPTIONS) CHENNAI CIRCLE, CHENNAI vs. THE COUNCIL OF SEVENTH DAY ADVENTIST EDUCATIONAL INSTITUTIONS, CHENNAI

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

ITA 1014/CHNY/2018[2010-11]Status: DisposedITAT Chennai25 Jul 2019AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy]

For Appellant: Shri. G.N. Raghavendra Rao, JCITFor Respondent: Shri. R.M. Narayanan, C.A
Section 11Section 12ASection 143(3)

…sses of earlier year and set off such losses against the income of the current year. 2.4 The Id. CIT(A) failed to consider the decision of ITAT, Delhi in the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases vs Dy.DIT (2009)29 SOT 316, ITAT, Chennai decisions in the case of Anjuman-E-Himayath-lslam vs.ADIT(Exemption) - IV, Chennai for the A.Y. 2009-10 reported in[2015] 59 taxmann.com 379 and M/s Inter Church Service Association in ITA NO.1253/Mds/2014 dated 05/02/2016. 2.5 The ld.CIT(A) failed to observe that carry forward of excess application of funds would result in notional…

DCIT (EXEMPTIONS) CHENNAI CIRCLE, CHENNAI vs. THE COUNCIL OF SEVENTH DAY ADVENTIST EDUCATIONAL INSTITUTIONS, CHENNAI

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

ITA 1013/CHNY/2018[2009-10]Status: DisposedITAT Chennai25 Jul 2019AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy]

For Appellant: Shri. G.N. Raghavendra Rao, JCITFor Respondent: Shri. R.M. Narayanan, C.A
Section 11Section 12ASection 143(3)

…sses of earlier year and set off such losses against the income of the current year. 2.4 The Id. CIT(A) failed to consider the decision of ITAT, Delhi in the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases vs Dy.DIT (2009)29 SOT 316, ITAT, Chennai decisions in the case of Anjuman-E-Himayath-lslam vs.ADIT(Exemption) - IV, Chennai for the A.Y. 2009-10 reported in[2015] 59 taxmann.com 379 and M/s Inter Church Service Association in ITA NO.1253/Mds/2014 dated 05/02/2016. 2.5 The ld.CIT(A) failed to observe that carry forward of excess application of funds would result in notional…

DCIT (EXEMPTIONS) CHENNAI CIRCLE, CHENNAI vs. THE COUNCIL OF SEVENTH DAY ADVENTIST EDUCATIONAL INSTITUTIONS, CHENNAI

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

ITA 1012/CHNY/2018[2008-09]Status: DisposedITAT Chennai25 Jul 2019AY 2008-09

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy]

For Appellant: Shri. G.N. Raghavendra Rao, JCITFor Respondent: Shri. R.M. Narayanan, C.A
Section 11Section 12ASection 143(3)

…sses of earlier year and set off such losses against the income of the current year. 2.4 The Id. CIT(A) failed to consider the decision of ITAT, Delhi in the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases vs Dy.DIT (2009)29 SOT 316, ITAT, Chennai decisions in the case of Anjuman-E-Himayath-lslam vs.ADIT(Exemption) - IV, Chennai for the A.Y. 2009-10 reported in[2015] 59 taxmann.com 379 and M/s Inter Church Service Association in ITA NO.1253/Mds/2014 dated 05/02/2016. 2.5 The ld.CIT(A) failed to observe that carry forward of excess application of funds would result in notional…

DCIT (EXEMPTIONS), CHENNAI vs. GREAT LAKES INSTITUTE OF MANAGEMENT, CHENNAI

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

ITA 2879/CHNY/2017[2011-12]Status: DisposedITAT Chennai29 Oct 2018AY 2011-12

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddyआयकर अपील सं./I T.A. No. 2879/Chny/2017 िनधा"रण वष"/Assessment Year:2011-12 The Deputy Commissioner Of M/S. Great Lakes Institute Of Income Tax (Exemption), Chennai Vs. Management, No. 24, South Mada Circle, Aayakar Bhavan, Annexe Street, Srinagar Colony, Saidapet, Building, Iii Floor, 121, M.G. Road, Chennai 600 015. Nungambakkam, Chennai – 600 034. [Pan:Aaccg2885L] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Maruda Pandian, Addl. Cit ""थ" की ओर से/Respondent By : None सुनवाई की तारीख/ Date Of Hearing : 11.09.2018 घोषणा की तारीख /Date Of Pronouncement : 29.10.2018 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals) 17, Chennai Dated 14.09.2017 Relevant To The Assessment Year 2011-12. The Only Effective Ground Raised In The Appeal Of The Revenue Is That The Ld. Cit(A) Has Erred In Holding That The Assessee Is Eligible To Set Off Of Brought Forward Excess Application Of Funds To Subsequent Years.

For Appellant: Shri Maruda Pandian, Addl. CITFor Respondent: None
Section 11Section 12ASection 142(1)Section 143(2)Section 143(3)

…Act and carry forward of the same to subsequent year to be set off against income of the subsequent year. By relying upon the decision of the Tribunal in the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases v. DDIT (2009) 29 SOT 316, in the case of Anjuman-E-Himayhath-Islam v. ADIT(E) [2015] 59 taxmann.com 379 (Chennai - Trib) as well as in the case of Inter Church Service Association in ITA No. 1253/Mds/2014 dated 05.02.2016, the ld. DR pleaded that the order of the ld. CIT(A) should be reversed. 5. Despite service of notice through DR, none appeared on behalf of the assess…

DCIT(E), NEW DELHI vs. DR. R.L. KHERA CHARITABLE TRUST, NEW DELHI

In the result, the appeal of the Revenue in ITA No

ITA 4132/DEL/2015[2011-12]Status: DisposedITAT Delhi20 Sept 2018AY 2011-12

Bench: Shri N.K. Billaiya & Shri N.K. Choudhary[Assessment Year: 2011-12] The Dy.C.I.T Vs. Dr. R.L. Khera Charitable Trust Circle 1(1) Pandav Nagar, Naraina Road New Delhi Near Shadipur Depot, New Delhi Pan : Aaatd 8903 D [Appellant] [Respondent]

For Appellant: Shri Hiren Mehta, CAFor Respondent: Ms. Asima Neb, Sr. DR
Section 11Section 11(1)Section 28Section 29Section 30Section 32Section 32(1)Section 34Section 43C

…issue is concerned relating to the claim of set off of carry forward of losses, though the ld. DR has placed strong reliance on the decision of the co-ordinate bench in the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases 29 SOT 316, but we find that the same is decided in favour of the assessee and against the Revenue by the decision of the Hon'ble jurisdictional High Court of Delhi in the case of Raghuvanshi Charitable Trust 197 Taxman 170 wherein the Hon'ble High Court was seized with the following questions of law: “a) Whether the Income Tax Appellate Tribunal was correc…

THE DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. THE KANTILAL JAIKISHANDAS CHOKSI CHARITABLE TRUST,, AHMEDABAD

In the result, appeal of the revenue is dismissed

ITA 1909/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad16 May 2018AY 2012-13

Bench: Shri Pramod Kumar & Shri Rajpal Yadavसव"ी Izeksn Dqekj Izeksn Dqekj Izeksn Dqekj लेखा सद"य, एवं राजपाल यादव "या"यक सद"य के सम"। Izeksn Dqekj आयकर अपील सं./ Ita No. 1909/Ahd/2016 "नधा"रण वष"/Assessment Year: 2012-13 Dcit(Exemptions), Kantilal Jaikishandas Choksi Circle-1, Vs Charitable Trust, Ahmedbad. Madhuban, Opp. Gujarat College, Madalpur, Ellisbridge, Ahmedabad. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaatk 1759 N अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri Saurabh Singh, Sr.D.R. Assessee By : Shri P. M. Mehta, A.R.

For Appellant: Shri P. M. Mehta, A.RFor Respondent: Shri Saurabh Singh, Sr.D.R
Section 11Section 11(2)Section 12ASection 143(2)Section 80G

…incurred in earlier years against the income of the relevant assessment years. In this respect the A.O has relied on the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases vs. Deputy Director of Income Tax (Exemption) [2009] 29 SOT 316 (Delhi) wherein it was held that when income accumulated in earlier years cannot qualify for exemption. U/s.11(2) the excess income applied for earlier assessment years would also not qualify for exemption. The appellant in its return for A.Y.2012-13 had reflected a deficit of Rs.2,51,34,291/- as per the computation of total income. The appellant…

OTC EXCHANGE OF INDIA,MUMBAI vs. ITO (E) 2(2), MUMBAI

In the result, appeals for the Assessment Years 2010-11 & 2011-12

ITA 7191/MUM/2016[2012-13]Status: DisposedITAT Mumbai26 Apr 2018AY 2012-13

Bench: Shri C.N. Prasad, Hon’Ble & Shri Ramit Kochar, Hon’Ble

For Appellant: Shri V. MohanFor Respondent: Shri M.C. Ningshen
Section 11Section 11(5)Section 13(2)(a)Section 154

…rsonnel Selection (supra). On a perusal of the Assessment Order, we noticed that the Assessing Officer relying on the decision of the Delhi Bench in the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases v. DDIT (Exemption) [29 SOT 316] and also taking note of the fact that the Department filed SLP against the Hon'ble Bombay High Court Judgment in the case of DIT v. Maharashtra Industrial Development Corporation (ITA.No. 2652 of 2011) which was admitted by the Hon'ble Supreme Court on the issue, the Assessing Officer held that allowing set off of brought forward deficit against…

OTC EXCHANGE OF INDIA,MUMBAI vs. ASST DIT (E) II(1), MUMBAI

In the result, appeals for the Assessment Years 2010-11 & 2011-12

ITA 7190/MUM/2016[2011-12]Status: DisposedITAT Mumbai26 Apr 2018AY 2011-12

Bench: Shri C.N. Prasad, Hon’Ble & Shri Ramit Kochar, Hon’Ble

For Appellant: Shri V. MohanFor Respondent: Shri M.C. Ningshen
Section 11Section 11(5)Section 13(2)(a)Section 154

…rsonnel Selection (supra). On a perusal of the Assessment Order, we noticed that the Assessing Officer relying on the decision of the Delhi Bench in the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases v. DDIT (Exemption) [29 SOT 316] and also taking note of the fact that the Department filed SLP against the Hon'ble Bombay High Court Judgment in the case of DIT v. Maharashtra Industrial Development Corporation (ITA.No. 2652 of 2011) which was admitted by the Hon'ble Supreme Court on the issue, the Assessing Officer held that allowing set off of brought forward deficit against…

OTC EXCHANGE OF INDIA,MUMBAI vs. ASST DIT (E) II(1), MUMBAI

In the result, appeals for the Assessment Years 2010-11 & 2011-12

ITA 7189/MUM/2016[2010-11]Status: DisposedITAT Mumbai26 Apr 2018AY 2010-11

Bench: Shri C.N. Prasad, Hon’Ble & Shri Ramit Kochar, Hon’Ble

For Appellant: Shri V. MohanFor Respondent: Shri M.C. Ningshen
Section 11Section 11(5)Section 13(2)(a)Section 154

…rsonnel Selection (supra). On a perusal of the Assessment Order, we noticed that the Assessing Officer relying on the decision of the Delhi Bench in the case of Pushpawati Singhania Research Institute for Liver, Renal & Digestive Diseases v. DDIT (Exemption) [29 SOT 316] and also taking note of the fact that the Department filed SLP against the Hon'ble Bombay High Court Judgment in the case of DIT v. Maharashtra Industrial Development Corporation (ITA.No. 2652 of 2011) which was admitted by the Hon'ble Supreme Court on the issue, the Assessing Officer held that allowing set off of brought forward deficit against…

THE DY. DIRECTOR OF INCOME TAX (EXEMPTION), AHMEDABAD vs. RAMANBHAI FOUNDATION,, AHMEDABAD

ITA 3035/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad18 Dec 2017AY 2011-12

Bench: Shri Rajpal Yadav & Shri N.K. Billaiya)

For Appellant: Shri Mudit Nagpal, Sr. D.RFor Respondent: Shri Jigar Patel, A.R

…IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “B” BENCH (BEFORE SHRI RAJPAL YADAV, JUDICIAL MEMBER & SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER) ITA. Nos: 3035 & 2964/AHD/2015 (Assessment Years: 2011-12 & 2012-13) Income Tax Officer, Ward V/S Ramanbhai Foundation, (Exemptions), Ward-2, Zydus Tower, Opp. Iskon Ahmedabad Temple, Satellite Cross road, Satellite, Ahmedabad-380015 PAN No. AAATR4358Q (Appellant) (Respondent) ITA. No: 2965/AHD/2015 (Assessment Year: 2011-12) Income Tax Officer, Ward V/S Olive International (Exemptions), Ward-2, Education Foundation, Plot Ahmedabad No. 126-127, Near Ahmedabad De…

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S.PANCHAJANYA VIDYA PEETA WELFARE TRUST, BANGALORE

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

ITA 1790/BANG/2016[2013-14]Status: DisposedITAT Bangalore29 Nov 2017AY 2013-14

Bench: Shri Arun Kumar Garodiaand Shri Laliet Kumar

For Appellant: Shri A. Shankar, AdvocateFor Respondent: Smt. Susan D. George, CIT (DR)
Section 11Section 11(1)(a)Section 70

…orward? 6 Whether on facts and in circumstances of the case, the Ld CIT(A) erred in not considering the decision of the Hon'ble ITAT, Delhi, in the case of Pushpavati Singhania Resaerch Institute for Lever, Renal and Digestive Diseases Vs. DDIT(E), New Delhi (29 SOT 316) which has held that any excess expenditure incurred by a trust/ charitable institution in earlier years cannot be allowed to be carried forward and set off against the income of subsequent assessment years? ITA Nos. 1785 to 1790/Bang/2016 & CO Nos. 52 to 57/Bang/2017 Page 3 of 11 7 Any other ground that may arise at the time of hearing.” 4. The…

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S.PANCHAJANYA VIDYA PEETA WELFARE TRUST, BANGALORE

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

ITA 1789/BANG/2016[2012-13]Status: DisposedITAT Bangalore29 Nov 2017AY 2012-13

Bench: Shri Arun Kumar Garodiaand Shri Laliet Kumar

For Appellant: Shri A. Shankar, AdvocateFor Respondent: Smt. Susan D. George, CIT (DR)
Section 11Section 11(1)(a)Section 70

…orward? 6 Whether on facts and in circumstances of the case, the Ld CIT(A) erred in not considering the decision of the Hon'ble ITAT, Delhi, in the case of Pushpavati Singhania Resaerch Institute for Lever, Renal and Digestive Diseases Vs. DDIT(E), New Delhi (29 SOT 316) which has held that any excess expenditure incurred by a trust/ charitable institution in earlier years cannot be allowed to be carried forward and set off against the income of subsequent assessment years? ITA Nos. 1785 to 1790/Bang/2016 & CO Nos. 52 to 57/Bang/2017 Page 3 of 11 7 Any other ground that may arise at the time of hearing.” 4. The…

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S.PANCHAJANYA VIDYA PEETA WELFARE TRUST, BANGALORE

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

ITA 1788/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Nov 2017AY 2011-12

Bench: Shri Arun Kumar Garodiaand Shri Laliet Kumar

For Appellant: Shri A. Shankar, AdvocateFor Respondent: Smt. Susan D. George, CIT (DR)
Section 11Section 11(1)(a)Section 70

…orward? 6 Whether on facts and in circumstances of the case, the Ld CIT(A) erred in not considering the decision of the Hon'ble ITAT, Delhi, in the case of Pushpavati Singhania Resaerch Institute for Lever, Renal and Digestive Diseases Vs. DDIT(E), New Delhi (29 SOT 316) which has held that any excess expenditure incurred by a trust/ charitable institution in earlier years cannot be allowed to be carried forward and set off against the income of subsequent assessment years? ITA Nos. 1785 to 1790/Bang/2016 & CO Nos. 52 to 57/Bang/2017 Page 3 of 11 7 Any other ground that may arise at the time of hearing.” 4. The…

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S.PANCHAJANYA VIDYA PEETA WELFARE TRUST, BANGALORE

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

ITA 1787/BANG/2016[2010-11]Status: DisposedITAT Bangalore29 Nov 2017AY 2010-11

Bench: Shri Arun Kumar Garodiaand Shri Laliet Kumar

For Appellant: Shri A. Shankar, AdvocateFor Respondent: Smt. Susan D. George, CIT (DR)
Section 11Section 11(1)(a)Section 70

…orward? 6 Whether on facts and in circumstances of the case, the Ld CIT(A) erred in not considering the decision of the Hon'ble ITAT, Delhi, in the case of Pushpavati Singhania Resaerch Institute for Lever, Renal and Digestive Diseases Vs. DDIT(E), New Delhi (29 SOT 316) which has held that any excess expenditure incurred by a trust/ charitable institution in earlier years cannot be allowed to be carried forward and set off against the income of subsequent assessment years? ITA Nos. 1785 to 1790/Bang/2016 & CO Nos. 52 to 57/Bang/2017 Page 3 of 11 7 Any other ground that may arise at the time of hearing.” 4. The…

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S.PANCHAJANYA VIDYA PEETA WELFARE TRUST, BANGALORE

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

ITA 1786/BANG/2016[2009-10]Status: DisposedITAT Bangalore29 Nov 2017AY 2009-10

Bench: Shri Arun Kumar Garodiaand Shri Laliet Kumar

For Appellant: Shri A. Shankar, AdvocateFor Respondent: Smt. Susan D. George, CIT (DR)
Section 11Section 11(1)(a)Section 70

…orward? 6 Whether on facts and in circumstances of the case, the Ld CIT(A) erred in not considering the decision of the Hon'ble ITAT, Delhi, in the case of Pushpavati Singhania Resaerch Institute for Lever, Renal and Digestive Diseases Vs. DDIT(E), New Delhi (29 SOT 316) which has held that any excess expenditure incurred by a trust/ charitable institution in earlier years cannot be allowed to be carried forward and set off against the income of subsequent assessment years? ITA Nos. 1785 to 1790/Bang/2016 & CO Nos. 52 to 57/Bang/2017 Page 3 of 11 7 Any other ground that may arise at the time of hearing.” 4. The…

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S.PANCHAJANYA VIDYA PEETA WELFARE TRUST, BANGALORE

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

ITA 1785/BANG/2016[2008-09]Status: DisposedITAT Bangalore29 Nov 2017AY 2008-09

Bench: Shri Arun Kumar Garodiaand Shri Laliet Kumar

For Appellant: Shri A. Shankar, AdvocateFor Respondent: Smt. Susan D. George, CIT (DR)
Section 11Section 11(1)(a)Section 70

…orward? 6 Whether on facts and in circumstances of the case, the Ld CIT(A) erred in not considering the decision of the Hon'ble ITAT, Delhi, in the case of Pushpavati Singhania Resaerch Institute for Lever, Renal and Digestive Diseases Vs. DDIT(E), New Delhi (29 SOT 316) which has held that any excess expenditure incurred by a trust/ charitable institution in earlier years cannot be allowed to be carried forward and set off against the income of subsequent assessment years? ITA Nos. 1785 to 1790/Bang/2016 & CO Nos. 52 to 57/Bang/2017 Page 3 of 11 7 Any other ground that may arise at the time of hearing.” 4. The…

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