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“Section 13(3)”

Section References (mined)Section 13Section 13(3)413 judgments

The decision most relied on for Section 13(3) is Engineering Analysis Centre of Excellence (P) Ltd. v. CIT (432 ITR 471), cited in 914 judgments on BharatTax.

Leading authorities on Section 13(3)

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. EKL Appliances Ltd.
345 ITR 241 · 2012 · High Court
422
citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

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.

ACIT v. Ahmedabad Urban Development Authority
143 Taxmann.com 278 · 2022 · Supreme Court
390
citing judgments

If activities for the advancement of general public utility are carried on as a business, income from such activities is not exempt under Section 11, even if the profits are utilized for the main charitable object. The argument that profits from general public utility activities can be ploughed back to charity to maintain exemption is not a good law.

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.

Judgments citing Section 13(3)

DCIT, Exemption Circle, Patna vs. Bijendra Memorial Society, Patna

In the result, the appeal is allowed

ITA 3/PAT/2021[2015-16]Status: DisposedITAT Patna29 Mar 2023AY 2015-16

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.3/Pat/2021 Assessment Year: 2015-16 Dcit (Exemption), Circle-Patna........……….........…..........….…… Appellant Vs. Bijendra Memorial Society….....….....……........…...…...…..…..... Respondent 404 Shyam Centre, Exhibition Road, Patna-800001. [Pan:Aabtb1511G] Appearances By: Shri Soumitra Choudhury, Adv., Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 01, 2023 Date Of Pronouncing The Order : March 29, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Revenue Against The Order Dated 28.08.2020 Of The Commissioner Of Income Tax (Appeals)-1, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Revenue In This Appeal Has Taken The Following Grounds Of Appeal: “1. The Ld.Cit(A) Has Erred In Law As Well As Facts Of The Case In Deleting The Additions Of Disallowances Towards The Salary/Remuneration Of Rs. 17,40,000/- & Rs.12,60,000/- Paid To Treasurer & Secretary Of The Trust & Rs.3,00,000/- To Shri Kala Choudhary For Hiring Of Bus & Rs.8,40,000/- For Hostel Building Rent To M/S Aadya Bhasker Enterprises Private Limited From The Income Of Trust Which Were Found Excessive & Unreasonable Under Sub-Section (3) Of Section 13 Of The

Section 12ASection 13Section 13(3)Section 143(3)Section 250

Shani Kumar, Treasurer of the Trust, of Rs.12,60,000/- was excessive. Since the above named persons were covered under the provisions of section 13(3) of the Act and the amount of salary paid was in excess of what may be reasonably paid for their services, therefore, he disallowed ... fact that the persons to whom this salary has been paid are covered by the definition of 'interested person" as per section 13(3). This however is more in the nature of conjecture as the assessment order is silent on any reasonable basis, discussion or result of any enquiry made

Gems Education Society, Gurgaon vs. ITO, Faridabad

ITA 2094/DEL/2017[2012-13]Status: DisposedITAT Delhi27 Mar 2023AY 2012-13

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2012-13 Gems Education Society Ito (Exemption) C-310, Unitech Business Vs Faridabad Zone, Nirvana Country, South City-Ii, Gurgaon - 122018 Pan No.Aaaag7454M (Appellant) (Respondent)

Section 13Section 13(3)

like recruitment services, drafting of curriculum, procurement services, accounting services etc., whilst learned Commissioner of Income Tax (Appeals) mechanically applied the provisions of Section 13 (3) of the Income Tax Act, 1961 and without giving due consideration of vis-a-vis documents provided by the assessee that Global Education Management ... such assumed that she is related with the management xo the payments were made to the benefit of person specified under section 13(3) of the Act. 3.2 The learned CIT (Appeal) misconstrued the provisions of Section 13, which carves out an exhaustive list of persons to whom such provisions

Guru Teg Bahadur Educational Trust, Jalandhar vs. Commissioner of Income Tax ( Exemptions), Chandigarh

In the result, appeal of the assessee is allowed

ITA 264/ASR/2022[2017-18]Status: DisposedITAT Amritsar14 Mar 2023AY 2017-18

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. K. Bhagat, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 12ASection 5

given to an organization, which has similar objects and no part of the same will go directly or indirectly to anybody specified in section 13(3) of the Income Tax Act, 1961. 3. In case the trust/institution is converted into any form, merged into any other entity or dissolved

Manohar Education Society, New Delhi vs. ITO(E) - Ward, Rohtak

In the result, the appeal of the assessee is partly allowed

ITA 7485/DEL/2019[2016-17]Status: DisposedITAT Delhi09 Mar 2023AY 2016-17

Bench: Shri Kul Bharat[Assessment Year : 2016-17] Manohar Education Society, Vs Ito(E), Prop. Cambridge School, Ward, Rohtak. Garhi Bolni Road, Rewari, Haryana. Pan-Aaatm6003F Appellant Respondent Appellant By None Respondent By Ms. Maimun Alam, Sr.Dr Date Of Hearing 02.02.2023 Date Of Pronouncement 09.03.2023

Section 10Section 13Section 13(3)Section 143(1)Section 164(2)Section 2(15)Section 250(6)

Learned CIT(A) has erred in law as well as on fact the rejection of use of Audi Car. Further the applying of Section 13(3) is also quite arbitrary and unjustified as none of the employee are in relation of the Trustee, Members or board of the society whose

DCIT (Exemption), Bhopal vs. M/S. All India Society for Electronics & Computer Technology, Bhopal

ITA 927/IND/2019[2013-14]Status: DisposedITAT Indore31 Jan 2023AY 2013-14

Bench: Ms.Suchitra Kamble & Shri B.M. Biyani

Section 11Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 2(15)

purpose” within the meaning of section 2(15) of the Act; and (ii) the assessee has extended benefit to the persons specified in section 13(3) which attracted the provisions of section 13(1)(c). With these observations, the Ld. AO denied exemption ... that the appellant has made any excessive or unreasonable payments to any of the concerns/person covered by the provisions of section 13(3).” The AO had observed that the appellant has undertaken various transactions with its associate concerns which have been undertaken with an object of diverting the income

Mahadevia Charitable Trust, Ahmedabad vs. Pr. CIT(Central), Jaipur

In the result, the appeal filed by the assessee is allowed

ITA 396/JODH/2019[2019-20]Status: DisposedITAT Jodhpur25 Jan 2023AY 2019-20

Bench: Shri B. R. Baskaran & Shri Sandeep Gosain

Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL JODHPUR BENCH, JODHPUR BEFORE SHRI B. R. BASKARAN, ACCOUNTANT MEMBER AND SHRI SANDEEP GOSAIN

M/S. Srinivas Institute of Medical Science and Research Centre, Mangalroe vs. The Principal Commissioner of Income Tax (Central), Bengaluru

In the result, the appeal filed by the assessee is allowed

ITA 533/BANG/2022[N/A]Status: DisposedITAT Bangalore30 Dec 2022

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: N.A.

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Dr. G. Manoj Kumar, D.R
Section 10Section 11Section 12ASection 269S

part of the same will go directly or indirectly to any of the beneficiaries of the society or anybody specified in section 13[3] of the Income-tax Act, 1961; the approval granted shall be subject to the provision of [6] proviso to section 143[3]; [7] the approval shall ... assessment proceedings that the income of the charitable trust is applied directly or indirectly for the benefit of the persons referred to in section 13(3), then he has ample power to deny exemption to that extent u/s.13

Panineeys Sanskrit Colleges Trust, Hyderabad vs. Income Tax Officer, (Exemptions)-3, Hyderabad

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

ITA 220/HYD/2022[2015-16]Status: DisposedITAT Hyderabad20 Dec 2022AY 2015-16

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2015-16 Panineeya Sanskrit Vs. Ito(Exemptions)-3 College Trust Aaykar Bhawan Sy.No.103, Basheerbagh Vivekananda Nagar Hyderabad-500 004 Dilsukhnagar Hyderabad-500 060

For Appellant: Shri A.V.Raghuram, AdvocateFor Respondent: Shri Kumar Aditya, Sr.AR
Section 11Section 120Section 12ASection 13(3)Section 143(2)Section 143(3)Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad Before Shri Rama Kanta Panda, Accountant Member AND Shri Laliet

DDIT, Chennai vs. Sri Vekkaliamman Educational and Charitable Trust, Chennai

In the result, appeal filed by the Revenue is dismissed

ITA 970/CHNY/2014[2010-11]Status: DisposedITAT Chennai14 Dec 2022AY 2010-11

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 970/Chny/2014 िनधा"रण वष" / Assessment Year: 2010-11 Deputy Director Of Income- M/S. Sri Vekkaliamman Tax (Exemptions)-Ii, V. Educational & Charitable Trust, Chennai – 34. No. 108, East Madha Street, Royapuram, Chennai – 600 013. [Pan: Aafts-7863-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. P. Sajit Kumar, Jcit ""यथ" क" ओर से/Respondent By : Shri. G. Seetharaman, Ca सुनवाई क" तारीख/Date Of Hearing : 01.12.2022 घोषणा क" तारीख/Date Of Pronouncement : 14.12.2022

For Appellant: Shri. P. Sajit Kumar, JCITFor Respondent: Shri. G. Seetharaman, CA
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)

High Court has given clear finding on violation committed by the trust u/s. 13(1)(c) r.w.s. 13(2) and section 13(3) of the Act, in respect of building contract awarded to a firm in which managing trustee was a partner and the firm having earned profit, whether

Parab Maratha Samaj, Mumbai vs. National Faceless Assessment Centre, Delhi

In the result, the appeal filed by the assessee stands partly allowed

ITA 1821/MUM/2022[2019-20]Status: DisposedITAT Mumbai30 Nov 2022AY 2019-20

Bench: Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 1821/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) Parab Maratha Samaj, Nfac, Delhi बिधम/ 10, 5Th Floor Mahohar Bldg, Priti Kanha, Chitable Path, Vs. Dadar(W), Mumbai-400 028 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaatp4197P (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Dinesh Shah, Ld. Ar प्रत्यथीकीओरसे/Respondent By : Ms. Neeta Jeph, Ld. Dr सुनवाईकीतारीख/ : 01.09.2022 Date Of Hearing घोषणाकीतारीख / : 30.11.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 09.05.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi For The Quantum Of Assessment Passed U/S 143(3) For Ay 2019-20. The Assessee Has Raised The Following Grounds Of Appeal:-

For Appellant: Shri Dinesh Shah, Ld. ARFor Respondent: Ms. Neeta Jeph, Ld. DR
Section 11Section 12ASection 143(3)

trust during the previous year used or applied directly or indirectly for the benefit of any person referred to in sub-section 13(3) (settler, author, trustee, etc). 13(1)(d) the charitable or religious institution or purposes makes investments other than those prescribed u/s 11(5) (eg- Shares

Dy.CIT (E) -2(1), Mumbai vs. Mumbai Educational Trust, Mumbai

ITA 1831/MUM/2022[2011-12]Status: DisposedITAT Mumbai30 Sept 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Sh. Rajesh DharapFor Respondent: Ms. Achal Sharma CIT DR
Section 10Section 10(33)Section 11Section 13Section 143(3)Section 147Section 148

erred in withdrawing the exemption U/s 11 of Act as property held under trust was given to interested party as defined in section 13(3) of the Act. The appellant further submitted in this ground of appeal without prejudice to the above ground to allow the benefit of the exemption ... assessee further submitted vide its letter dated: 15/03/2016 as follows; With regard to your honour's show cause as to why provision of section 13(3) and 13(2) should not be invoked in assessee's case as property of the trust is used by related party M/s. Ideen Furniture

Dy.CIT (E) -2(1), Mumbai vs. Mumbai Educational Trust, Mumbai

ITA 1830/MUM/2022[2010-11]Status: DisposedITAT Mumbai30 Sept 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Sh. Rajesh DharapFor Respondent: Ms. Achal Sharma CIT DR
Section 10Section 10(33)Section 11Section 13Section 143(3)Section 147Section 148

erred in withdrawing the exemption U/s 11 of Act as property held under trust was given to interested party as defined in section 13(3) of the Act. The appellant further submitted in this ground of appeal without prejudice to the above ground to allow the benefit of the exemption ... assessee further submitted vide its letter dated: 15/03/2016 as follows; With regard to your honour's show cause as to why provision of section 13(3) and 13(2) should not be invoked in assessee's case as property of the trust is used by related party M/s. Ideen Furniture

Dy.CIT (E) -2(1), Mumbai vs. Mumbai Educational Trust, Mumbai

ITA 1829/MUM/2022[2009-10]Status: DisposedITAT Mumbai30 Sept 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Sh. Rajesh DharapFor Respondent: Ms. Achal Sharma CIT DR
Section 10Section 10(33)Section 11Section 13Section 143(3)Section 147Section 148

erred in withdrawing the exemption U/s 11 of Act as property held under trust was given to interested party as defined in section 13(3) of the Act. The appellant further submitted in this ground of appeal without prejudice to the above ground to allow the benefit of the exemption ... assessee further submitted vide its letter dated: 15/03/2016 as follows; With regard to your honour's show cause as to why provision of section 13(3) and 13(2) should not be invoked in assessee's case as property of the trust is used by related party M/s. Ideen Furniture

Dy.CIT (E) -2(1), Mumbai vs. Mumbai Educational Trust, Mumbai

ITA 1828/MUM/2022[2008-09]Status: DisposedITAT Mumbai30 Sept 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Sh. Rajesh DharapFor Respondent: Ms. Achal Sharma CIT DR
Section 10Section 10(33)Section 11Section 13Section 143(3)Section 147Section 148

erred in withdrawing the exemption U/s 11 of Act as property held under trust was given to interested party as defined in section 13(3) of the Act. The appellant further submitted in this ground of appeal without prejudice to the above ground to allow the benefit of the exemption ... assessee further submitted vide its letter dated: 15/03/2016 as follows; With regard to your honour's show cause as to why provision of section 13(3) and 13(2) should not be invoked in assessee's case as property of the trust is used by related party M/s. Ideen Furniture

Vile Parle Mahila Sangh, Mumbai-400057 vs. Commissioner of Income Tax (Exemptions), Mumbai-400026

In the result, appeal filed by the assessee is allowed

ITA 1066/MUM/2022[2017-18]Status: DisposedITAT Mumbai21 Sept 2022AY 2017-18

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Ms Kavitha Rajagopal, Hon'Blevile Parle Mahila Sangh V. Cit (Exemptions) Mangalayatan, Paranjpe B Scheme Room No. 601, 6Th Floor Road No. 1, Vile Parle (E) Mtnl Te Building, Pedder Road Mumbai - 400057 Dr. Gopal Rao Deshmukh Marg Cumballa Hill, Mumbai – 400026 Pan: Aaatv2407Q (Appellant) (Respondent) Assessee Represented By : Mandar Vaidya Department Represented By : Achal Sharma

Section 11(2)Section 119(2)Section 12ASection 139Section 143(3)Section 263

income u/s. 11(1)(a) of the Act and also details of amount paid during the previous year to any person referred in section 13(3) of the Act. Further, he brought to our notice additions declared by the assessee in its return of income u/s. 11(3

Shree Aniruddha Upasana Foundation, Mumbai vs. CIT (Exemption), Mumbai

In the result, the appeal filed by the assessee is In the result, the appeal filed by the assessee is allowed

ITA 706/MUM/2022[2017-18]Status: DisposedITAT Mumbai19 Sept 2022AY 2017-18

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2017-18 Shree Aniruddha Upasana Cit (Exemption), Foundation, 601, 6Th Floor, Cumballa Hills Flat No. 702, Link Apartment, Vs. Mtnl Te Building, Pedder Tps Iii, Khari Village, Road, Dr. Gopalrao Deshmukh Khar (West), Marg, Cumballa Hill, Mumbai-400052. Mumbai-400026. Pan No. Aaics 9217 L Appellant Respondent Assessee By : Snehal Shah, Ar Revenue By : Smt. Shailja Rai, Cit-Dr Date Of Hearing : 01/08/2022 Date Of Pronouncement : 19/09/2022

For Appellant: Snehal Shah, ARFor Respondent: Smt. Shailja Rai, CIT-DR
Section 11(2)Section 143(3)Section 2Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI KULDIP SINGH (JUDICIAL MEMBER) AND SHRI OM PRAKASH

The Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 66/BANG/2018[2014-15]Status: DisposedITAT Bangalore29 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

ITA Nos.2775, 2776 & 2777/Bang/2017 ITA Nos.64, 65 & 66/Bang/2018 & ITA Nos.235 & 236/Bang/2018 IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 65/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

ITA Nos.2775, 2776 & 2777/Bang/2017 ITA Nos.64, 65 & 66/Bang/2018 & ITA Nos.235 & 236/Bang/2018 IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 64/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Aug 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

ITA Nos.2775, 2776 & 2777/Bang/2017 ITA Nos.64, 65 & 66/Bang/2018 & ITA Nos.235 & 236/Bang/2018 IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. Sri V C Charantimath, Bagalkot

In the result, the assessee’s appeals in ITA Nos

ITA 236/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

ITA Nos.2775, 2776 & 2777/Bang/2017 ITA Nos.64, 65 & 66/Bang/2018 & ITA Nos.235 & 236/Bang/2018 IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE