“Section 10(21)”

ASIA SOCIETY INDIA CENTRE,MUMBAI vs. INCOME TAX OFFICER, (EXEMPTION)-1(1), MUMBAI

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

different assessment year. The relevant extract of the aforesaid judgments of the Hon’ble Delhi High Court reads as under: “2. Section 10(21) provides for exemption of any income of a scientific research association which is approved under section 35(1)(ii) The first proviso, however, makes the exemption ... exemption from tax, does not relate to the previous year in which the contingency took place. This, in short, is the substance of section 10(21) read with section 11(2) and (3) of the Act. 3. The petitioner is a scientific research society approved by the competent authority under

DY. COMMISSIONER OF INCOME TAX(EXEMPTIONS)-2(1), MUMBAI, MUMBAI vs. SOCIETY FOR APPLIED MICROWAVE ELECTRONICS ENGINEERING AND RESEARCH, MUMBAI

In the result, the appeal of the revenue is dismissed

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahayassessment Year: 2013-14 Dy. Commissioner Of Society For Applied Income Tax Microwave Electronics (Exemption)- 2(1) Engineering & Room No. 608, Research 6Th Floor, Sameer, Mtnl, Vs. Iit Campus, Peddar Road, Hill Side, Cumbala Hill, Mumbai- 400076. Maharashtra – 400026. Pan: Aalas5825K (Appellant) (Respondent)

activities of the assessee are that of pure research work, the assessee is required to be assessed to tax under the provisions of section 10(21) of the Act subject to the fulfillment of the conditions laid down therein and not under the provisions of section ... scientific field. Therefore, the benefit of section 11 cannot be allowed to the assessee. The Ld. AO also held that the provisions of section 10 (21) of the Act are applicable in the case of the assessee which provides that the assessee was required to obtain approval from the Central

DY. COMMISSIONER OF INCOME TAX(EXEMPTIONS)-2(1), MUMBAI, MUMBAI vs. SOCIETY FOR APPLIED MICROWAVE ELECTRONIC ENGINEERING RESEARCH BOMBAY, MUMBAI

In the result, the appeal of the learned Assessing Officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Dy. Commissioner Of Income Society For Applied Microwave Tax (Exemptions)-2(1), Electronic Engineering Room No.608, 6Th Floor, Mtnl Research Bombay Vs. Peddar Road, Cumbala Hill, Iit Campus, Hill Slde, Powai, Mumbai-400 026 Mumbai-400 076 (Appellant) (Respondent) Pan No. Aalas5825K Assessee By : Ms. Ritu Panjabi, Ar Revenue By : Shri Dr. Kishor Dhule, Cit Dr Date Of Hearing: 24.06.2024 26.07.2024 Date Of Pronouncement :

activities of the assessee are pure research work, the assessee is required to be taxed and assessed under Section 10(21) of the Act subject to fulfillment of conditions. It was noticed that assessee claiming it to be an autonomous research and development institute under the control of department ... from Ministry of Science and Technology for availing Custom Duty Exemption and on the same line assessee should have applied for exemption under Section 10(21) of the Act. Further, to avail the benefit of Section 10(21) of the Act the assessee should have been approved under that Section

DCIT(E)1(1), MUMBAI vs. INDIAN REGISTER OF SHIPING, MUMBAI

In the result, the appeal of the revenue is allowed for statistical purpose

Bench: Shri Amit Shukla & Smt. Renu Jauhridcit(E)1(1) V/S Indian Register Of Room No. 607, 6Th Floor, बनाम Shipping, Mtnl Building, Cumballa 52A, Adi Shankaracharya Hill, Marg, Apposite Powai Mumbai-400026 Lake, Mumbai-400072 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaci2381M Appellant/अपीलार्थी .. Respondent/प्रतिवादी

category of ‘other institution’ partly engaged in research activities. As such the assessee is not covered under the provisions of section 10(21) which allows exemption of income only to a ‘research association’ and not to the other categories such as university, college or other institution mentioned in section ... Relevant portion of the Section 10(21) is reproduced as under: “10.(21) any income of a [research association] for the time being approved for the purpose of clause (ii) [or clause (iii)] of sub-section (1) of section 35: Provided that the research association— ……. ……. ……” Page

DEPUTY COMMISSIONER OF INCOME-TAX(EXEMPTION)-2(1), MUMBAI, MUMBAI vs. SOCIETY FOR APPLIED MICROWAVE ELECTRONIC ENGINEERING AND RESEARCH (SAMEER), MUMBAI

In the result, all the appeals filed by the Revenue and assessee are treated as allowed for statistical purposes”

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singh & Deputy Commissioner Vs. Society For Applied Microwave Electronic Of Income Tax Engineering & (Exemption)-2(1), Research (Sameer) 6Th Floor, Iit Campus, Mtnl Telephone Hill Side,Powai, Exchange Building, Mumbai-400076. Dr.Gd Deshmukhmarg, Peddar Road, Cumbala Hill, Mumbai -400026. Pan/Gir No.Aalas5825K (अपीलाथ"/Appellant) (""यथ"/Respondent)

relied by him is related to section 10(23C)/10(38)/10(33) of the Income-tax act and not to that section 10(21) of the Income-tax Act, 1961. 3. The brief facts of the case are that, the assessee society is an autonomous body carrying on research ... Since the assessee’s activities are of pure research work and the assessee is required to comply with the provisions of section 10(21) of the Act. The assessee has filed the detailed submissions on the activities in the assessment proceedings referred at Para3.1 of the order. Whereas

THE SYNTHETIC & ART SILK MILLS RESEARCH ASSOCIATION,MUMBAI vs. CIT (EXEM), MUMBAI

In the result, the appeal of assessee is allowed

Bench: Smt. Kavitha Rajagopal, Jm & Ms Padmavathy S, Am

assessee being engaged in carrying out research activities and being notified under section 35(1)(ii) is entitled to the benefit under section 10(21) of the Act. The assessee vide letter dated 31.10.2018 also filed the revised computation claiming deduction under section 10(21) of the Act before ... r.w.s. 147 of the Act accepted the alternate submission of the assessee held that the assessee's income is exempt under section 10(21) of the Act and accordingly completed the assessment assessing the income at Rs. Nil. 4. The CIT(Exemption) (herein after "First CIT(Exemption)"), Mumbai on perusal