Queen’s Educational Society v. CIT

372 ITR 699Supreme Court of India2015#653 most cited

What is Queen’s Educational Society v. CIT authority for?

An educational institution that generates a surplus does not automatically lose its charitable status or cease to exist solely for educational purposes. This is true if the surplus is reinvested for its educational objectives, and the predominant object test determines if the institution's primary aim is education or profit.

152

judgments rely on this decision, according to BharatTax’s citation analysis of 370,744 Indian tax judgments — from 2011 to 2026.

Also referred to as

Queen's Educational Society v. CIT · Section 11 · Section 10(23C) · Section 2(15) · Section 12A · educational institution surplus · charitable purpose profit motive · predominant object test · income tax exemption

Also reported as

55 Taxmann.com 255

Sections most often in play

Section 11Section 12AASection 143(3)Section 142(1)Section 2(15)Section 10(23C)(v)Section 12ASection 139(4A)
Read the full judgment

Issues it is cited on

section 13(1)(c)(ii)section 10(22)section 158asection 13(3)section 10(23c)(vi)proviso to section 2(15)section 13(1)(c)section 13(1)interest free advancessection 10(23c)section 2(15)application of income

Judgments citing Queen’s Educational Society v. CIT

Income Tax Officer (Exemption), Ward-1(1), Mumbai vs. Association of Physicians of Indiaf, Mumbai

In the result, Ground No.1 of the assessee‟s appeal is allowed

ITA 973/MUM/2022[2016-17]Status: DisposedITAT Mumbai30 Jun 2022AY 2016-17
Section 11Section 143Section 2(15)Section 28

…ed. 11.3 The courts have stated that if the activities are being carried on as part of charitable object, it cannot be said to be in the nature of trade, commerce or business. The Hon‟ble Supreme Court in the case of Queen‟s Educational Society vs. CIT [2015] 372 ITR 699 (SC) has held that a surplus arising from activities would not necessarily mean that institution is being carried on „for profit‟. The Hon‟ble Gujarat High Court in the case of DIT(Exemption) vs. Gujarat Cricket Association Tax Appeal No. 123 of 2014 judgment dated 27.09.2019 inter alia observed that the profits, if any, ploughed back into the ve…

Income Tax Officer(Exemption)Ward-1(1), Mumbai vs. Association of Physicians of India, Mumbai

In the result, Ground No.1 of the assessee‟s appeal is allowed

ITA 972/MUM/2022[2015-16]Status: DisposedITAT Mumbai30 Jun 2022AY 2015-16
Section 11Section 143Section 2(15)Section 28

…ed. 11.3 The courts have stated that if the activities are being carried on as part of charitable object, it cannot be said to be in the nature of trade, commerce or business. The Hon‟ble Supreme Court in the case of Queen‟s Educational Society vs. CIT [2015] 372 ITR 699 (SC) has held that a surplus arising from activities would not necessarily mean that institution is being carried on „for profit‟. The Hon‟ble Gujarat High Court in the case of DIT(Exemption) vs. Gujarat Cricket Association Tax Appeal No. 123 of 2014 judgment dated 27.09.2019 inter alia observed that the profits, if any, ploughed back into the ve…

Income Tax Officer (Exemption) Ward-1(1), Mumbai vs. Association of Physicians of India, Mumbai

In the result, Ground No.1 of the assessee‟s appeal is allowed

ITA 971/MUM/2022[2014-15]Status: DisposedITAT Mumbai30 Jun 2022AY 2014-15
Section 11Section 143Section 2(15)Section 28

…ed. 11.3 The courts have stated that if the activities are being carried on as part of charitable object, it cannot be said to be in the nature of trade, commerce or business. The Hon‟ble Supreme Court in the case of Queen‟s Educational Society vs. CIT [2015] 372 ITR 699 (SC) has held that a surplus arising from activities would not necessarily mean that institution is being carried on „for profit‟. The Hon‟ble Gujarat High Court in the case of DIT(Exemption) vs. Gujarat Cricket Association Tax Appeal No. 123 of 2014 judgment dated 27.09.2019 inter alia observed that the profits, if any, ploughed back into the ve…

Indian Academy of Highway Engineers, Noida vs. CIT(E), Lucknow

ITA 645/DEL/2021[----]Status: DisposedITAT Delhi30 Jun 2022

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 645 /Del/2021 (Assessment Year : ……..)

Section 10

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘C’ : NEW DELHI) (Through Video Conferencing) BEFORE SH. G.S.PANNU, HON’BLE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No. 645 /Del/2021 (Assessment Year : ……..) Indian Academy of Highway Vs. CIT(Exemptions) Engineers Lukhnow, A-5, Industrial Area, Sec-62, Noida PAN : AABAI2196K (APPELLANT) (RESPONDENT) Assessee by Sh. Akhilesh Kumar, Adv. Sh. Vipin Garg, Adv. Revenue by Ms. Deepshikha Sharma, CIT(DR) Date of hearing: 10.06.2022 Date of Pronouncement: 30.06.2022 ORDER PER ANUBHAV SHARMA, JM: The appeal has been preferred by the assessee…

Income Tax Officer (Exemptions), Ward, Jaipur vs. Rajasthan Cricket Association, Jaipur

In the result, appeal of the Department is dismissed

ITA 68/JPR/2022[2013-14]Status: DisposedITAT Jaipur21 Jun 2022AY 2013-14

Bench: The Hon’Ble Tribunal In The Interest Of Justice.

For Appellant: Shri Shyam Lal Agarwal, CAFor Respondent: Ms Manisha Chandra, CIT fu/kZkfjrh dh vksj ls@
Section 11Section 12ASection 143(3)Section 147Section 148Section 2(15)

…r section 13(3) and in view of the provisions of section 13(1), the assessee society is not held eligible for exemption under section 11 of the Act. 15. Here, we refer to the decision of Hon'ble Supreme Court in case of Queen's Education Society v. CIT [2015] 372 ITR 699/231 Taxman 286/55 taxmann.com 255 where relevant principles of law have been laid down to determine whether an educational institution exists solely for educational purposes and not for profit. In that case, the provisions of section 10(23C)(iiiad) of the Act were under consideration of Hon'ble Supreme Court . The Revenue therein has argued that…

Income Tax Officer (Exemption), Ward, Jaipur vs. Rajasthan Cricket Association, Jaipur

In the result, appeal of the Department is dismissed

ITA 67/JPR/2022[2012-13]Status: DisposedITAT Jaipur21 Jun 2022AY 2012-13

Bench: The Hon’Ble Tribunal In The Interest Of Justice.

For Appellant: Shri Shyam Lal Agarwal, CAFor Respondent: Ms Manisha Chandra, CIT fu/kZkfjrh dh vksj ls@
Section 11Section 12ASection 143(3)Section 147Section 148Section 2(15)

…r section 13(3) and in view of the provisions of section 13(1), the assessee society is not held eligible for exemption under section 11 of the Act. 15. Here, we refer to the decision of Hon'ble Supreme Court in case of Queen's Education Society v. CIT [2015] 372 ITR 699/231 Taxman 286/55 taxmann.com 255 where relevant principles of law have been laid down to determine whether an educational institution exists solely for educational purposes and not for profit. In that case, the provisions of section 10(23C)(iiiad) of the Act were under consideration of Hon'ble Supreme Court . The Revenue therein has argued that…

Income Tax Officer, Jaipur vs. Rajasthan Cricket Association, Jaipur

In the result, appeal of the Department is dismissed

ITA 66/JPR/2022[2005]Status: DisposedITAT Jaipur21 Jun 2022

Bench: The Hon’Ble Tribunal In The Interest Of Justice.

For Appellant: Shri Shyam Lal Agarwal, CAFor Respondent: Ms Manisha Chandra, CIT fu/kZkfjrh dh vksj ls@
Section 11Section 12ASection 143(3)Section 147Section 148Section 2(15)

…r section 13(3) and in view of the provisions of section 13(1), the assessee society is not held eligible for exemption under section 11 of the Act. 15. Here, we refer to the decision of Hon'ble Supreme Court in case of Queen's Education Society v. CIT [2015] 372 ITR 699/231 Taxman 286/55 taxmann.com 255 where relevant principles of law have been laid down to determine whether an educational institution exists solely for educational purposes and not for profit. In that case, the provisions of section 10(23C)(iiiad) of the Act were under consideration of Hon'ble Supreme Court . The Revenue therein has argued that…

Assistant Commissioner of Income-Tax, (Exemption) Circle, Aurangabad vs. M/S. the Nanded Sikhgurudwara Sachkhand Hazur Apchalnagar Sahib, Nanded

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

ITA 2119/PUN/2017[2014-15]Status: DisposedITAT Pune09 Jun 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.2119/Pun/2017 िनधा"रण वष" / Assessment Year: 2014-15 Acit, Exemption Circle, Vs. M/S. The Nanded Aurangabad. Sikhgurudwara Sachkhand Hazur Apchalnagar Sahib, Nanded-431601. Pan : Aabtt2452Q Appellant Respondent Revenue By : Shri Sardar Singh Meena Assessee By : Shri Nikhil S. Pathak Date Of Hearing 26.05.2022 : Date Of Pronouncement : 09.06.2022 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Revenue Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)- 2, Aurangabad [‘Cit(A)’ For Short] Dated 06.06.2017 For The Assessment Year 2014-15. 2. The Revenue Raised The Following Grounds Of Appeal :- “1. The Ld. Cit(A), Has Erred In Allowing Exemption U/S 10(23C)(V) Of The Act, In The Given Facts Of The Case, Particularly The Assessee Failed To Furnish Audit Report In Form No. 10Bb U/S 10(23C)(V) R.W.R. 16Cc.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Sardar Singh Meena
Section 10Section 11Section 12ASection 143(3)

…t-assessee trust generated surplus of funds of 41% of gross receipts and inferred that the funds were not utilized for the object for which the respondent-assessee trust was formed. The Hon’ble Supreme Court in the case of Queen's Educational Society vs. CIT, 372 ITR 699 (SC) held that merely because a charitable trust had generated surplus does not lead to conclusion that the appellant trust is not charitable or religious exiting for the purpose of profit. To the similar effect in the decision of the Hon’ble 9 Supreme Court in the case of Aditanar Educational Institution vs. Addl.CIT, 224 ITR 310 (SC). Therefor…

M/S. Nabadigant Educational Trust, Bhubaneswar vs. ITO, Ward-2(1), Bhubaneswar

In the result, both appeals of the assessee are dismissed

ITA 137/CTK/2016[2011-12]Status: DisposedITAT Cuttack17 May 2022AY 2011-12
For Appellant: Shri B.R.Pattnaik, ARFor Respondent: Shri M.K.Goutam, CIT-DR
Section 11Section 12ASection 13Section 13(1)(c)Section 13(1)(d)Section 13(2)(a)Section 143(2)Section 143(3)Section 80G

…आयकर अपीऱीय अधिकरण, कटक न्यायपीठ,कटक IN THE INCOME TAX APPELLATE TRIBUNAL CUTTACK BENCH CUTTACK BEFORE SHRI C.M. GARG, JM & SHRI ARUN KHODPIA, AM आयकर अपीऱ सं./ITA No.03/CTK/2015 & आयकर अपीऱ सं./ITA No.137/CTK/2016 (नििाारण वषा / Assessment Year :2009-2010 & 2011-2012) M/s Nabadigant Educational Trust, Vs ITO, Ward-2(1), Bhubaneswar Plot No.N.2/17, IRC Village, Bhubaneswar-751015 PAN No. : AAATN 3196 L (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee by : Shri B.R.Pattnaik, AR िाजस्व की ओर से /Revenue by : Shri M.K.Goutam, CIT-DR सुनवाई की तािीख / Date of Hearing : 07/03/2022 घोषणा…

M/S. Nabadigant Educational Trust, Bhubaneswar vs. ITO, Ward-2(1), Bhubaneswar

In the result, both appeals of the assessee are dismissed

ITA 3/CTK/2015[2009-10]Status: DisposedITAT Cuttack17 May 2022AY 2009-10
For Appellant: Shri B.R.Pattnaik, ARFor Respondent: Shri M.K.Goutam, CIT-DR
Section 11Section 12ASection 13Section 13(1)(c)Section 13(1)(d)Section 13(2)(a)Section 143(2)Section 143(3)Section 80G

…आयकर अपीऱीय अधिकरण, कटक न्यायपीठ,कटक IN THE INCOME TAX APPELLATE TRIBUNAL CUTTACK BENCH CUTTACK BEFORE SHRI C.M. GARG, JM & SHRI ARUN KHODPIA, AM आयकर अपीऱ सं./ITA No.03/CTK/2015 & आयकर अपीऱ सं./ITA No.137/CTK/2016 (नििाारण वषा / Assessment Year :2009-2010 & 2011-2012) M/s Nabadigant Educational Trust, Vs ITO, Ward-2(1), Bhubaneswar Plot No.N.2/17, IRC Village, Bhubaneswar-751015 PAN No. : AAATN 3196 L (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee by : Shri B.R.Pattnaik, AR िाजस्व की ओर से /Revenue by : Shri M.K.Goutam, CIT-DR सुनवाई की तािीख / Date of Hearing : 07/03/2022 घोषणा…

Sri Keshav Prasad Singh Shikshan Sanshan, Varanasi vs. CIT (E), Lucknow

In the result, the appeal of the assessee in ITA no

ITA 320/ALLD/2017[2017-2018]Status: DisposedITAT Varanasi22 Apr 2022AY 2017-2018

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriRahul R. Gabhawala, C.AFor Respondent: Shri Sunil Kumar Bajpai, CIT DR
Section 80GSection 80G(5)Section 80G(5)(vi)

…nsthan, Varanasi file),which also contains written submissions rebutting findings of ld. CIT(E). The ld. Counsel for the assessee relied upon the judgment and order of Hon’ble Supreme Court in the case of Queen’s Educational Society v. CIT, reported in (2015) 372 ITR 699(SC).The ld. Counsel for the assessee prayed that since there are factual errors in the order passed by ld. CIT(E), the matter may be restored back to the file of ld. CIT(E) for denovo consideration of the assessee’s application for grant of registration/approval u/s 80G(5), so that the assessee can produce books of accounts, vouchers and other ev…

Sant Kachacha Baba Lok Sewa Trust, Varanasi vs. CIT (E), Lucknow

In the result, the appeal of the assessee in ITA no

ITA 319/ALLD/2017[2017-2018]Status: DisposedITAT Varanasi22 Apr 2022AY 2017-2018

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriRahul R. Gabhawala, C.AFor Respondent: Shri Sunil Kumar Bajpai, CIT DR
Section 80GSection 80G(5)Section 80G(5)(vi)

…ced on record in file),which also contains written submissions rebutting findings of ld. CIT(E). The ld. Counsel for the assessee relied upon the judgment and order of Hon’ble Supreme Court in the case of Queen’s Educational Society v. CIT, reported in (2015) 372 ITR 699(SC).The ld. Counsel for the assessee prayed that since there are factual errors in the order passed by ld. CIT(E), the matter may be restored back to the file of ld. CIT(E) for denovo consideration of the assessee’s application for grant of registration/approval u/s 80G(5), so that the assessee can produce books of accounts, vouchers and other ev…

Jawaharlal Nehru Technological University, Kakinada vs. The Commissioner of Income Tax ( Exemptions), Hyderabad

In the result, appeal of the assessee is allowed

ITA 671/VIZ/2019[2019-2020]Status: DisposedITAT Visakhapatnam07 Apr 2022AY 2019-2020

Bench: Shri Duvvuru R L Reddy, Hon’Ble & Shri S. Balakrishnan, Hon'Ble

For Appellant: Sri G.V.N. HariFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 11Section 12A

…n the activities carried by the asessee such a 6 violation may not be a ground for refusal for grant of registration U/s. 12A of the Act. He placed reliance on the decision of the Hon’ble Supreme Court in the case of Queen’s Educational Society vs. CIT [2015] 55 Taxmann.com 255 (SC). The Ld. Counsel for the assessee pleaded that similar direction may be granted to the assessee as well. 5. The Ld. DR on the other hand argued that the assessee has made huge profits as observed by the Ld. CIT(E) in para 4 of his order. Ld. DR also supported the order of the Ld. CIT(E). 6. Considering the rival contentions and the…

Commissioner of Income Tax, (Exemption), Kolkata vs. The Neotia University

The appeal is dismissed and the substantial question of

ITAT/28/2018HC Calcutta13 Dec 2021

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 115TSection 12ASection 260ASection 45Section 80G

…ect will have preference over the second alternative wherein ti has been provided that the property shall vest in the State Government. The Tribunal rightly referred to the decision of the Hon’ble Supreme Court in Queen’s Educational Society – vs- CIT [(2012) 372 ITR 699 (SC)]. The learned Counsel for the respondent/assessee submitted that the respondent/trust has been formed by the Government for the purpose of creating a corpus for providing facilities to the public who are in the West Bengal Municipal area. Further, reliance has been placed on the decision of High Court of Rajasthan in Commission…

The Association of Physician of India, Mumbai vs. Asst Director of Income Tax (E) II (2), Mumbai

In the result, Ground No.1 of the assessee‟s appeal is allowed

ITA 3162/MUM/2019[2013-14]Status: DisposedITAT Mumbai08 Sept 2021AY 2013-14
Section 11Section 12ASection 143(3)Section 2(15)

…ia 11.3 The courts have stated that if the activities are being carried on as part of charitable object, it cannot be said to be in the nature of trade, commerce or business. The Hon‟ble Supreme Court in the case of Queen‟s Educational Society vs. CIT [2015] 372 ITR 699 (SC) has held that a surplus arising from activities would not necessarily mean that institution is being carried on „for profit‟. The Hon‟ble Gujarat High Court in the case of DIT(Exemption) vs. Gujarat Cricket Association Tax Appeal No. 123 of 2014 judgment dated 27.09.2019 inter alia observed that the profits, if any, ploughed back into the ve…

DCIT (Exemption), Ghaziabad vs. Ram Nath Memorial Trust Society, Meerut

In the result appeal filed by the revenue is dismissed

ITA 2557/DEL/2018[2014-15]Status: DisposedITAT Delhi19 Aug 2021AY 2014-15

Bench: Shri N.K. Billaiya & Shri Pawan Singhasstt. Year: 2014-15

For Appellant: Shri Rohit Agarwal, AdvocateFor Respondent: Ms. Mrinalini Sapra, Sr. DR
Section 12ASection 68

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”: NEW DELHI (THROUGH VIDEO CONFERENCING) BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER Asstt. Year: 2014-15 DCIT (Exemption) Ram Nath Memorial Trust Ghaziabad Society Vs. Ram Bagh Colony, Shastri Nagar, Meerut Uttar Pradesh PAN AAATT6054B (Appellant) (Respondent) Department by: Ms. Mrinalini Sapra, Sr. DR Assessee by : Shri Rohit Agarwal, Advocate Date of Hearing 17/08/2021 Date of Pronouncement 19/08/2021 O R D E R PER PAWAN SINGH, JUDICIAL MEMBER: This appeal filed by the Revenue is directed against the order of Ld. CIT(A…

M/S Step by Step Junior School Society, Amritsar vs. Commissioner of Income Tax (Exemption), Chandigarh

ITA 596/ASR/2016[2015-16]Status: DisposedITAT Amritsar16 Aug 2021AY 2015-16

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 10

…here could be no manner of doubt that the surplus accumulated over the years had been ploughed back for educational purposes and in the said case the Hon'ble Apex Court reminded the conditions of principle laid down in Queen's Education Society vs. CIT [2015] 372 ITR 699 (SC) which for the sake of brevity and convenience are reproduced herein below. "11. Thus, the law common to section 10(23C)(iiiad) and (vi) may be summed up as follows. (1) Where an educational institution carries on the activity of education primarily for educating persons, the fact that it makes a surplus does not lead to the conclusion that…

DCIT, Exemption Circle, Ghaziabad vs. Major Shiv Dayal Singh Chikitsa Trust, Farrukhabad

In the result, the appeal of the Revenue is dismissed

ITA 5849/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Jul 2021AY 2014-15

Bench: Shri Kul Bharat & Shri O.P. Kant[Through Video Conferencing] Assessment Year: 2014-15

Section 11Section 12ASection 164(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER [Through Video Conferencing] Assessment Year: 2014-15 DCIT, Vs. Major Shiv Dayal Singh Exemption Circle, Chikitsa Trust, Ghaziabad Phoos Bangla, Civil Lines, Fatehgarh, Farrukhabad PAN :AABTM7636F (Appellant) (Respondent) Appellant by Ms. Pramita M. Biswas, CIT(DR) Respondent by Sh. Abhinav Malhotra, Adv. Date of hearing 13.07.2021 Date of pronouncement 29.07.2021 ORDER PER O.P. KANT, AM: This appeal by the Revenue is directed against order dated 19/06/2017 passed by…

The Sardar Partapsingh Education Society, Mumbai vs. The CIT (Exemptions), Mumbai

In the result, appeal of the assessee is allowed

ITA 487/MUM/2021[2019-20]Status: DisposedITAT Mumbai11 Jun 2021AY 2019-20
Section 10

…the case of Vanita Vishram Trust vs. CCIT reported in 327 ITR 121 (Bom). b) Decision of Hon’ble Madras High Court in the case of PKD Trust vs. ITO reported in 311 CTR 657. c) Hon’ble Supreme Court in the case of Queens Educational Society vs. CIT reported in 372 ITR 699 (SC) d) Decision of the Hon’ble Supreme Court in the case of Vishvesvaraya Tech University vs. ACIT reported in 384 ITR 37. e) Decision of Hon’ble Supreme Court in the case of CCIT vs. St. Peters Educational Society reported in 385 ITR 66. 8 The Sardar Partapsingh Education Society 3.1. Moreover, the Hon’ble Supreme Court in the case of American…

DCIT, C-1, (E), Chandigarh vs. M/S Manav Mangal Society, Chandigarh

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

ITA 30/CHANDI/2020[2016-17]Status: DisposedITAT Chandigarh27 May 2021AY 2016-17
For Appellant: Shri Sudhir Sehgal, AdvFor Respondent: Shri Sandeep Dahiya, CIT-DR
Section 13(3)

…आयकर अपील"य अ"धकरण,च"डीगढ़ "यायपीठ “बी”, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “B”, CHANDIGARH (VIRTUAL COURT) "ी एन.के.सैनी, उपा"य" एवं "ी आर.एल. नेगी, "या"यक सद"य BEFORE: SHRI. N.K.SAINI, VP & SHRI R.L. NEGI, JM आयकर अपील सं./ ITA Nos. 02 & 03/Chd/2020 "नधा"रण वष" / Assessment Years : 2010-11 & 2011-12 M/s Manav Mangal Society, Dy. Commissioner of Income Tax, बनाम Sector-21-C, Circle-1, (Exemptions), Chandigarh. Chandigarh. "थायी लेखा सं./PAN NO: AAAAM0564C अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ ITA Nos. 136 & 137/Chd/2020 "नधा"रण वष" / Assessment Years : 2010-11 & 2011-12 D…