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“Section 13(1)”

Section References (mined)Section 13Section 13(1)715 judgments

The decision most relied on for Section 13(1) is Engineering Analysis Centre of Excellence (P) Ltd. v. CIT (432 ITR 471), cited in 914 judgments on BharatTax.

Leading authorities on Section 13(1)

Engineering Analysis Centre of Excellence (P) Ltd. v. CIT
432 ITR 471 · 2021 · Supreme Court
914
citing judgments

Payments for the supply or use of computer software, where there is no transfer of copyright but only a right to use the copyrighted product, are generally considered business profits and not 'royalty' or 'fees for technical services' under the Income Tax Act, 1961 or relevant DTAAs. This principle also applies to transponder fees, which are not taxable as royalty.

Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT
374 ITR 118 · 2015 · High Court
499
citing judgments

The existence of an international transaction for Advertising and Marketing Promotion (AMP) expenditure requires the revenue to discharge the burden of proof. An explanation inserted under Section 92B does not automatically make AMP expenditure an international transaction.

CIT v. Samsung Electronics Ltd.
345 ITR 494 · 2012 · High Court
461
citing judgments

Payments by Indian residents to non-resident foreign software suppliers for software are considered royalty, constituting income deemed to accrue in India under section 9(1)(v), thereby requiring tax deduction at source under section 195.

CIT v. Institute of Banking Personnel Selection
264 ITR 110 · 2003 · High Court
398
citing judgments

Depreciation is allowable on assets for which the cost has been fully allowed as an application of income under Section 11 in previous years, when computing the income of a charitable trust. Charitable trusts are also entitled to carry forward their deficit.

Ishikawajima Harima Heavy Industries Ltd. v. DIT
288 ITR 408 · 2007 · Supreme Court
394
citing judgments

Income from offshore supply of goods and services is not taxable in India if the entire transaction, including transfer of ownership and payments, occurs outside India.

CIT v. De Beers India Minerals (P.) Ltd.
346 ITR 467 · 2012 · High Court
371
citing judgments

For fees for technical or consultancy services to 'make available' technical knowledge or know-how under a DTAA, the service must transmit such knowledge, allowing the recipient to derive an enduring benefit and utilize it independently in the future.

Asia Satellite Telecommunications Co. Ltd. v. DIT
332 ITR 340 · 2011 · High Court
359
citing judgments

Payments for the use of equipment, such as satellite transponders, do not constitute 'royalty' under Section 9(1)(vi) of the Income-tax Act, 1961, or under applicable tax treaties, especially when there is no transfer of the right to use a process or underlying technology.

DIT v. New Skies Satellite BV
382 ITR 114 · 2016 · High Court
325
citing judgments

An amendment to the Income Tax Act, such as the Finance Act, 2012 amendment to Section 9(1)(vi) defining royalty, does not automatically override or alter the definition of 'royalty' as provided in a Double Taxation Avoidance Agreement (DTAA) unless the DTAA itself is bilaterally amended. The definition of royalty in a DTAA remains unaffected by unilateral changes to domestic law.

Judgments citing Section 13(1)

DCIT 26(1), Mumbai, Bkc vs. Tata Social Welfare Trust, Mumbai

In the result, appeals are dismissed

ITA 2486/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10Section 10(34)Section 11Section 13(1)(d)Section 143(3)Section 147Section 164(2)Section 3Section 7

case, the Ld. CIT(A) is justified in allowing the assessee appeal despite the fact that there is violation of provisions of section 13(1)(d) of the I.T. Act because of the investment by the Trust in prohibited mode of investment that it would lead?" 2. Whether, 1 ... that the investment made by the assessee in the shares of Tata Sons Ltd. is in clear violation of the provisions of the Section 13(1)(d) of the Income Tax Act, 1961 and ignoring the decision of Hon'ble Supreme Court in the case of Bharat Diamond Bourse

Dy. Commissioner of Income Tax 26(1), Mumbai vs. Tata Social Welfare Trust, Mumbai

In the result, appeals are dismissed

ITA 2485/MUM/2025[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10Section 10(34)Section 11Section 13(1)(d)Section 143(3)Section 147Section 164(2)Section 7

case, the Ld. CIT(A) is justified in allowing the assessee appeal despite the fact that there is violation of provisions of section 13(1)(d) of the I.T. Act because of the investment by the Trust in prohibited mode of investment that it would lead?" 2. Whether, 1 ... that the investment made by the assessee in the shares of Tata Sons Ltd. is in clear violation of the provisions of the Section 13(1)(d) of the Income Tax Act, 1961 and ignoring the decision of Hon'ble Supreme Court in the case of Bharat Diamond Bourse

Dy. Commissioner of Income Tax, Mumbai vs. Tata Social Welfare Trust, Mumbai

In the result, appeals are dismissed

ITA 2484/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Oct 2025AY 2010-11

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10Section 10(34)Section 11Section 13(1)(d)Section 143(3)Section 147Section 164(2)Section 3Section 7

case, the Ld. CIT(A) is justified in allowing the assessee appeal despite the fact that there is violation of provisions of section 13(1)(d) of the I.T. Act because of the investment by the Trust in prohibited mode of investment that it would lead?" 2. Whether, 1 ... that the investment made by the assessee in the shares of Tata Sons Ltd. is in clear violation of the provisions of the Section 13(1)(d) of the Income Tax Act, 1961 and ignoring the decision of Hon'ble Supreme Court in the case of Bharat Diamond Bourse

Dy. Commissioner of Income Tax 26(1), Mumbai, Kautilya Bhawan, Bkc vs. Tata Social Welfare Trust, Mumbai

In the result, appeals are dismissed

ITA 2483/MUM/2025[2008-09]Status: DisposedITAT Mumbai10 Oct 2025AY 2008-09

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10Section 10(34)Section 11Section 13(1)(d)Section 143(3)Section 147Section 164(2)Section 3Section 7

case, the Ld. CIT(A) is justified in allowing the assessee appeal despite the fact that there is violation of provisions of section 13(1)(d) of the I.T. Act because of the investment by the Trust in prohibited mode of investment that it would lead?" 2. Whether, 1 ... that the investment made by the assessee in the shares of Tata Sons Ltd. is in clear violation of the provisions of the Section 13(1)(d) of the Income Tax Act, 1961 and ignoring the decision of Hon'ble Supreme Court in the case of Bharat Diamond Bourse

Tata Social Welfare Trust, Mumbai vs. ACIT-17(3), Mumbai

In the result, appeals are dismissed

ITA 2475/MUM/2025[2015-16]Status: DisposedITAT Mumbai10 Oct 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10Section 10(34)Section 11Section 13(1)(d)Section 143(3)Section 147Section 164(2)Section 3Section 7

case, the Ld. CIT(A) is justified in allowing the assessee appeal despite the fact that there is violation of provisions of section 13(1)(d) of the I.T. Act because of the investment by the Trust in prohibited mode of investment that it would lead?" 2. Whether, 1 ... that the investment made by the assessee in the shares of Tata Sons Ltd. is in clear violation of the provisions of the Section 13(1)(d) of the Income Tax Act, 1961 and ignoring the decision of Hon'ble Supreme Court in the case of Bharat Diamond Bourse

Assistant Commissioner of Income Tax, Kautilya Bhavan, Bkc, Mumbai vs. Tata Education Trust, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4852/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

also agreed with the AO that the assessee did violate the conditions of Section 13(1)(d) and 13(2)(h) of the Act. Thereafter, relying upon a decision of Hon’ble Madras High Court in case of CIT vs. Working Women’s Forum [2015] 53 taxmann.com 85 (Madras ... held that the maximum marginal rate would apply only to dividend income of Rs.10,55,25,000/- as it is in violation of Sections 13(1)(d) and 13(2)(h) of the Act. In so far as interest income of Rs.74,48,000/- and other income of Rs.1

Tata Education Trust, Mumbai vs. Assistant Commissioner of Income Tax-17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4835/MUM/2024[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

exemption u/s.10(34) and 10(35) of the Act. He also agreed with the AO that the assessee did violate the conditions of Section 13(1)(d) and 13(2)(h) of the Act. Thereafter, relying upon a decision of Hon'ble Madras High Court in case ... held that the maximum marginal rate would apply only to dividend income of Rs.10,55,25,000/- as it is in violation of Sections 13(1)(d) and 13(2)(h) of the Act. In so far as interest income of Rs.74,48,000/- and other income of Rs.1

Tata Education Trust, Mumbai vs. Assistant Commissiioner of Income Tax Circle 17(3), Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4727/MUM/2024[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

also agreed with the AO that the assessee did violate the conditions of Section 13(1)(d) and 13(2)(h) of the Act. Thereafter, relying upon a decision of Hon’ble Madras High Court in case of CIT vs. Working Women’s Forum [2015] 53 taxmann.com 85 (Madras ... held that the maximum marginal rate would apply only to dividend income of Rs.10,55,25,000/- as it is in violation of Sections 13(1)(d) and 13(2)(h) of the Act. In so far as interest income of Rs.74,48,000/- and other income of Rs.1

Tata Education Trust, Mumbai vs. Assistant Commissioner of Income Tax Circle -17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4496/MUM/2024[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

exemption u/s.10(34) and 10(35) of the Act. He also agreed with the AO that the assessee did violate the conditions of Section 13(1)(d) and 13(2)(h) of the Act. Thereafter, relying upon a decision of Hon'ble Madras High Court in case ... held that the maximum marginal rate would apply only to dividend income of Rs.10,55,25,000/- as it is in violation of Sections 13(1)(d) and 13(2)(h) of the Act. In so far as interest income of Rs.74,48,000/- and other income of Rs.1

Assistant Commissioner of Income Tax- 26(1), Mumbai vs. Tata Education Trust, Mumbai

In the result, Revenue's appeal is dismissed

ITA 4419/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

exemption u/s.10(34) and 10(35) of the Act. He also agreed with the AO that the assessee did violate the conditions of Section 13(1)(d) and 13(2)(h) of the Act. Thereafter, relying upon a decision of Hon'ble Madras High Court in case ... held that the maximum marginal rate would apply only to dividend income of Rs.10,55,25,000/- as it is in violation of Sections 13(1)(d) and 13(2)(h) of the Act. In so far as interest income of Rs.74,48,000/- and other income of Rs.1

Tata Education Trust, Mumbai vs. Deputy Commissioner of Income Tax (Exeption) -Circle 2(1), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4283/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

exemption u/s.10(34) and 10(35) of the Act. He also agreed with the AO that the assessee did violate the conditions of Section 13(1)(d) and 13(2)(h) of the Act. Thereafter, relying upon a decision of Hon'ble Madras High Court in case ... held that the maximum marginal rate would apply only to dividend income of Rs.10,55,25,000/- as it is in violation of Sections 13(1)(d) and 13(2)(h) of the Act. In so far as interest income of Rs.74,48,000/- and 5 ITA Nos.4282

Tata Education Trust, Mumbai vs. Deputy Commissioner of Income Tax (Exemption)-Circle 2(1), Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4282/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

also agreed with the AO that the assessee did violate the conditions of Section 13(1)(d) and 13(2)(h) of the Act. Thereafter, relying upon a decision of Hon’ble Madras High Court in case of CIT vs. Working Women’s Forum [2015] 53 taxmann.com 85 (Madras ... held that the maximum marginal rate would apply only to dividend income of Rs.10,55,25,000/- as it is in violation of Sections 13(1)(d) and 13(2)(h) of the Act. In so far as interest income of Rs.74,48,000/- and other income of Rs.1

Tata Education Trust, Mumbai vs. ACIT-17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4156/MUM/2024[2015-16]Status: DisposedITAT Mumbai10 Oct 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w Shri Sukhsagar & Shri Atul SuraiyaFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

exemption u/s.10(34) and 10(35) of the Act. He also agreed with the AO that the assessee did violate the conditions of Section 13(1)(d) and 13(2)(h) of the Act. Thereafter, relying upon a decision of Hon'ble Madras High Court in case ... held that the maximum marginal rate would apply only to dividend income of Rs.10,55,25,000/- as it is in violation of Sections 13(1)(d) and 13(2)(h) of the Act. In so far as interest income of Rs.74,48,000/- and other income of Rs.1

Dy. Commissioner of Income Tax (Exemptions), Circle, Pune, Swargate vs. Shri Mukund Bhavan Trust, Pune

In the result, the appeal of the Revenue is dismissed

ITA 829/PUN/2025[2017-2018]Status: DisposedITAT Pune08 Oct 2025AY 2017-2018

Bench: Shri Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.829 & 827/Pun/2025 धििाारण वर्ा / Assessment Years : 2017-18 & 2018-19 Dy. Commissioner Of Shri Mukund Bhavan Trust, Income Tax (Exemptions), 1105, Ravivar Peth, Pune-411002 Cirlce – Pune Vs. Pan : Aaats5170R अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assesseeby : Shri V.L. Jain Department By : Shri Amol Khairnar Date Of Hearing : 24-07-2025 Date Of 08-10-2025 Pronouncement :

For Appellant: Shri V.L. JainFor Respondent: Shri Amol Khairnar
Section 11Section 12ASection 13Section 13(1)Section 13(1)(c)Section 13(2)(b)Section 13(3)Section 143(2)Section 3

benefit of exemption may not be disallowed and income may not be assessed as an AOP if violation of the provisions of section 13(1)(c)(ii) and section 13(2)(b) of the Act exists in AY 2017-18 under consideration. The assessee filed its reply to the said ... section 13 of the Act and accordingly no question of treating the assessee as an AOP arises. Further, referring to proviso to section 13(1) of the Act, the assessee submitted that the trust is created by a trust deed executed on 10.02.1930 (i.e. much prior to the enactment

Dy. Commissioner of Income Tax (Exemptions), Circle, Pune, Swargate vs. Shri Mukund Bhavan Trust, Pune

In the result, the appeal of the Revenue is dismissed

ITA 827/PUN/2025[2018-2019]Status: DisposedITAT Pune08 Oct 2025AY 2018-2019

Bench: Shri Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.829 & 827/Pun/2025 धििाारण वर्ा / Assessment Years : 2017-18 & 2018-19 Dy. Commissioner Of Shri Mukund Bhavan Trust, Income Tax (Exemptions), 1105, Ravivar Peth, Pune-411002 Cirlce – Pune Vs. Pan : Aaats5170R अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assesseeby : Shri V.L. Jain Department By : Shri Amol Khairnar Date Of Hearing : 24-07-2025 Date Of 08-10-2025 Pronouncement :

For Appellant: Shri V.L. JainFor Respondent: Shri Amol Khairnar
Section 11Section 12ASection 13Section 13(1)Section 13(1)(c)Section 13(2)(b)Section 13(3)Section 143(2)Section 3

benefit of exemption may not be disallowed and income may not be assessed as an AOP if violation of the provisions of section 13(1)(c)(ii) and section 13(2)(b) of the Act exists in AY 2017-18 under consideration. The assessee filed its reply to the said ... section 13 of the Act and accordingly no question of treating the assessee as an AOP arises. Further, referring to proviso to section 13(1) of the Act, the assessee submitted that the trust is created by a trust deed executed on 10.02.1930 (i.e. much prior to the enactment

Clg Universal Foundation, Jodhpur vs. CIT(Exemption), Jaipur

In the result, ITAs 192 & 280/Jodh/2024 are allowed and ITA

ITA 280/JODH/2024[2023-24]Status: DisposedITAT Jodhpur29 Sept 2025AY 2023-24

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

Section 12ASection 12A(1)(ac)Section 13(1)(c)Section 2(15)Section 8Section 80G(5)

finding regarding the charitable objects or the identity of the trust. Therefore, rejection of registration merely on the ground of alleged violations under Section 13(1)(c) was wholly unjustified. The Ld. AR invited our attention to copy of rent agreement, details of amount spent on various activities and Audited ... that the assessee had not carried out genuine charitable activities and that the alleged transactions amounted to siphoning of funds in violation of Section 13(1)(c) of the Act. It is a settled proposition of law that at the stage of granting registration under Section 12AB, the scope

Clg Universal Foundation, Jodhpur vs. CIT ( Exemption), Jaipur

In the result, ITAs 192 & 280/Jodh/2024 are allowed and ITA

ITA 227/JODH/2024[2023-24]Status: DisposedITAT Jodhpur29 Sept 2025AY 2023-24

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

Section 12ASection 12A(1)(ac)Section 13(1)(c)Section 2(15)Section 8Section 80G(5)

finding regarding the charitable objects or the identity of the trust. Therefore, rejection of registration merely on the ground of alleged violations under Section 13(1)(c) was wholly unjustified. The Ld. AR invited our attention to copy of rent agreement, details of amount spent on various activities and Audited ... that the assessee had not carried out genuine charitable activities and that the alleged transactions amounted to siphoning of funds in violation of Section 13(1)(c) of the Act. It is a settled proposition of law that at the stage of granting registration under Section 12AB, the scope

Clg Universal Foundation, Jodhpur vs. CIT(Exemption), Jaipur

In the result, ITAs 192 & 280/Jodh/2024 are allowed and ITA

ITA 192/JODH/2024[2023-24]Status: DisposedITAT Jodhpur29 Sept 2025AY 2023-24

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

Section 12ASection 12A(1)(ac)Section 13(1)(c)Section 2(15)Section 8Section 80G(5)

finding regarding the charitable objects or the identity of the trust. Therefore, rejection of registration merely on the ground of alleged violations under Section 13(1)(c) was wholly unjustified. The Ld. AR invited our attention to copy of rent agreement, details of amount spent on various activities and Audited ... that the assessee had not carried out genuine charitable activities and that the alleged transactions amounted to siphoning of funds in violation of Section 13(1)(c) of the Act. It is a settled proposition of law that at the stage of granting registration under Section 12AB, the scope

Holyfaith Tribal W and D Trust, Ranchi vs. ITO Exemption Ward, Ranchi

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

ITA 69/RAN/2024[2016-17]Status: DisposedITAT Ranchi29 Sept 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Before Shri Sonjoy Sarma & Before Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayshri Ratnesh Nandan Sahayshri Ratnesh Nandan Sahay(Virtual Hearing) Holyfaith Tribal W & D Trust, Ranchi, Holyfaith Tribal W & D Trust, Ranchi, I.T.O., 406, Midland East Apartment, 406, Midland East Apartment, Exemption Ward, Exemption Ward, Vs. Anantpur, Chutia, Doranda, Anantpur, Chutia, Doranda, Ranchi. Ranchi-834002 (Jharkhand) 834002 (Jharkhand) Pan No. Aaath 5200 R Aaath 5200 R Appellant/ Assessee Appellant/ Assessee Respondent/ Revenue Respondent/ Revenue

Section 11Section 13(1)Section 133(6)Section 17

alleging that the assessee For that the revenue authorities were not justified in alleging that the assessee has violated the provisions of Section 13(1) and 13(3) of the Income has violated the provisions of Section 13(1) and 13(3) of the Income has violated the provisions ... Section 13(1) and 13(3) of the Income-tax Act, 1961 (the Act) and as such, the exemption claimed U/s 11 and 12 is 1961 (the Act) and as such, the exemption claimed U/s 11 and 12 is 1961 (the Act) and as such, the exemption claimed

Amreli Modh Vanik Community Property, Amreli vs. The Pr. CIT(Exemption), Ahmedabad

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

ITA 360/RJT/2024[2024-25]Status: DisposedITAT Rajkot29 Sept 2025AY 2024-25

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.360/Rjt/2024 "नधा"रण वष"/ Assessment Year: 2024-25 Amreli Modh Vanik Principal Commissioner Of Community Property बनाम Income-Tax(Exemption), Nr. Rajkamal Chowk, Amreli- /Vs. Ahmedabad, 365 601 Room No.609, 6Th Floor, Ayakar Bhawan (Vejalpur), Nr. Sacin Tower 100 Ft Road, Anandnagar Prahladnagar Road, Ahmedabad-3800 015 "थायीलेखासं /.जीआइआरसं . / Pan/Gir No.: Aagta 8104 R (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia Cit-Dr

For Appellant: Shri Mehul Ranpura, ld.ARFor Respondent: Shri Sanjay Punglia CIT-DR
Section 12ASection 12A(1)(ac)Section 80G(5)

benefit of public at large. Therefore, please clarify that as to how there is no contravention of provision of section 13(1)(b) of the Act. 3. Hence, you are requested to show cause as to why your application filed in Form 10AB u/s 12A(1)(ac)(iii) should ... preceding 3 years, if yes, furnish the copy of order. 10 State as to whether the objects are for any particular Provisions of section 13(1)((b) will not be applicable due caste, creed and religious community. to the reasons and brief notes mentioned in Annexure A mentioned