“accumulation of income”

Charitable TrustsSection 11(2)Section 11(2)359 judgments

The decision most relied on for accumulation of income is Lissie Medical Institutions v. CIT (348 ITR 344), cited in 164 judgments on BharatTax.

Leading authorities on accumulation of income

Lissie Medical Institutions v. CIT

348 ITR 344 · 2012 · High Court

164

citing judgments

The Kerala High Court held that charitable institutions claiming exemption under Section 11 are not entitled to claim depreciation on assets used for charitable purposes, taking a view contrary to most other High Courts.

CIT v. Raj Kumar

318 ITR 462 · 2009 · High Court

119

citing judgments

Genuine trade advances made by a company in the ordinary course of business to a shareholder do not fall within the definition of deemed dividend under Section 2(22)(e) of the Income-tax Act.

CIT v. Nagpur Hotel Owners Association

247 ITR 201 · 2001 · Supreme Court

112

citing judgments

While there is no statutory time limit for filing Form 10 to claim exemption for income accumulation under Section 11(2), it must be furnished before the completion of assessment proceedings for the Assessing Officer to grant the exemption.

CIT v. Rao Bahadur Calavala Cunnan Chetty Charities

135 ITR 485 · 1982 · High Court

citing judgments

The income of a charitable trust, particularly income from property held under trust, for the purpose of claiming exemption under Section 11, must be computed in a normal commercial manner, without strict reference to the computation provisions for different heads of income like Section 14 or Section 24(a). This approach ensures that the income available for application or accumulation is assessed on commercial principles.

CIT v. Programme for Community Organisation

248 ITR 1 · 2001 · Supreme Court

citing judgments

The 15% exemption available to charitable trusts under Section 11(1)(a) is absolute and is not curtailed by the provisions of Section 11(2) regarding accumulation of income. Voluntary contributions received towards the corpus of a trust are excluded from the scope of income for Section 11(1)(a) exemption purposes.

CIT v. Programme for Community Organisation

228 ITR 620 · 1997 · High Court

citing judgments

For charitable or religious trusts, income for exemption under Sections 11 and 12 must be computed on a commercial basis, not head-wise as per Section 14, treating expenditure as a charge against income. The net income, along with non-corpus donations, forms the eligible base for determining the application of funds and the permissible accumulation under Section 11(1)(a).

CIT v. Mayur Foundation

274 ITR 562 · 2005 · High Court

citing judgments

The Gujarat High Court held that Form No. 10, for exercising the option under section 11(2) to accumulate income, can be submitted during assessment proceedings, including before the Income Tax Appellate Tribunal, which is a continuation of assessment proceedings. Such submission constitutes sufficient compliance for claiming exemption under section 11.

ACIT v. A.L.N. Rao Charitable Trust

216 ITR 697 · 1995 · Supreme Court

citing judgments

The exemption for income accumulated under section 11(1)(a) (presently 15%) is absolute, and section 11(2) does not restrict its operation or require such accumulated income to be invested in specified securities. Investment requirements under section 11(2) apply only to accumulation beyond this absolute exemption limit.

Judgments citing accumulation of income

Dy. Commissioner of Income Tax, (Exemption)-2(1), Mumbai vs. Trans Thane Creek Waste Management Association, Mumbai

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

ITA 1559/MUM/2023[2012-2013]Status: DisposedITAT Mumbai25 Jul 2023AY 2012-2013

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2012-13 Dy. Cit (Exemption)-2(1), Trans Thane Creek Waste Room No. 608, 6Th Floor, Mtnl Management Association, Vs. Building, Cumballa Hill, P-128, Next To L & T Infotech Mumbai-400026. Ltd., Shill Mahape Road, Navi Mumbai-400701. Pan No. Aadct 4375 R Appellant Respondent

For Appellant: NoneFor Respondent: Mr. Prakash D. Choughule, DR

Section 11(1)Section 11(1)(a)Section 12ASection 143(3)Section 154Section 25

however, the Ld. Assessing Officer in his order u/s 154 of the Act /s 154 of the Act dated 04.09.2019 restricted the accumulation of income u/s 11(1) dated 04.09.2019 restricted the accumulation of income u/s 11(1) dated 04.09.2019 restricted the accumulation of income ... property income received from the property, which means gross receipt which means gross receipt has to be considered for the purpose of the accumulation of income. ed for the purpose of the accumulation of income. Th ed for the purpose of the accumulation of income. provisions

Ayyappa Seva Samgham Bombay Trust, Mumbai vs. CIT (A)-53, Mumbai

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 134/MUM/2023[2016-17]Status: DisposedITAT Mumbai18 Jul 2023AY 2016-17

Bench: Shri B.R. Baskaran (Am) & Shri Narendra Kumar Choudhary (Jm)

Section 11Section 11(1)Section 11(1)(a)Section 11(6)Section 12A

assessing corpus donations as normal donations and also did not consider depreciation as an application of income. While computing the deduction for accumulation of income allowable u/s 11(1)(a) of the Act, the AO did not allow the correct amount. Accordingly, the total income of the assessee trust ... relating to corpus donation and depreciation. He directed the AO to allow correct amount of deduction u/s 11(1) of the Act towards accumulation of income. Aggrieved, the assessee has filed this appeal before the Tribunal. 5. The first issue relates to the assessment of Corpus donations received

Vaibhav Global Limited, Jaipur vs. DCIT, Central Circle-4, Jaipur

In the result, the appeal of the assessee is allowed

ITA 96/JPR/2023[2017-18]Status: DisposedITAT Jaipur14 Jul 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajeev Sogani, CA &For Respondent: Shri A.S. Nehra, Addl.CIT

Section 143(1)Section 143(1)(a)Section 154Section 36(1)(va)

regular assessment, then question that needs to be considered is whether the Assessing Officer can make adjustments towards capital gains and accumulation of income u/s.11(2) of the Income Tax Act, 1961, while processing return u/s.143(1) of the Act. The provisions of section 143(1) deals with summary adjustment ... writing or electronic mode.In this case, admittedly no such intimation was given to the assessee before making adjustment towards capital gain and accumulation of income u/s.11(2) of the Income Tax Act, 1961. Therefore, on this count itself adjustment made by the Assessing Officer towards capital gain and accumulation

National Institute of Bank Management, Mumbai vs. ACIT, Exemption, Circle-1, Mumbai

In the result, the appeal filed by the assessee for AY 2015-16 is partly allowed for statistical purposes and both the appeal filed by the assessee for AY

ITA 756/MUM/2023[2017-18]Status: DisposedITAT Mumbai05 Jul 2023AY 2017-18

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

For Respondent: Shri S. Ananthan & Ms. Lalitha

Section 10Section 11Section 11(2)Section 12ASection 250Section 80G

Income Tax (Appeals) erred in not allowing depreciation as allowable expenditure. 3.4.1. The learned Commissioner of Income Tax (Appeals) erred in not allowing accumulation of income u/s. 11(2) of the Act. 4. The learned Commissioner of Income Tax (Appeals) erred in not adjudicating the ground relating to treating capital

National Institute of Bank Management, Mumbai vs. DCIT (Exemption)-2(1), Mumbai

In the result, the appeal filed by the assessee for AY 2015-16 is partly allowed for statistical purposes and both the appeal filed by the assessee for AY

ITA 755/MUM/2023[2015-16]Status: DisposedITAT Mumbai05 Jul 2023AY 2015-16

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

For Respondent: Shri S. Ananthan & Ms. Lalitha

Section 10Section 11Section 11(2)Section 12ASection 250Section 80G

National Institute of Bank Management, Mumbai vs. ACIT, Exemption, Circle-2, Mumbai

In the result, the appeal filed by the assessee for AY 2015-16 is partly allowed for statistical purposes and both the appeal filed by the assessee for AY

ITA 754/MUM/2023[2016-17]Status: DisposedITAT Mumbai05 Jul 2023AY 2016-17

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

For Respondent: Shri S. Ananthan & Ms. Lalitha

Section 10Section 11Section 11(2)Section 12ASection 250Section 80G

Sri Dattatreya Sai Ashram Trust, Bhubaneswar vs. ITO Exemption, Bhubaneswar

In the result, appeal of the assessee is allowed

ITA 98/CTK/2023[2014-15]Status: DisposedITAT Cuttack26 Jun 2023AY 2014-15

For Appellant: Shri S.K.Sarangi, CAFor Respondent: Shri S.C.Mohanty, Sr. DR

Section 1Section 139Section 143(1)Section 251Section 251(1)(a)

processed income if required. The ld. CIT(A) did not direct the AO to re-examine the allowability or not of the accumulation of income. This being so, clearly the ld. AO while passing the order u/s.251/143(1) of the Act dated 28.12.2018 while giving effect to the order

Mukesh Parshottambhai Mangukiya, Surat vs. ITO Ward-3(2)(5), Surat

In the result, this ground of appeal is partly allowed

ITA 247/SRT/2022[2017-18]Status: DisposedITAT Surat15 Jun 2023AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Mukesh Parshottambhai Mangukiya, I.T.O., 58-59, Jalaram Society, Ved Road, Ward-3(2)(5) Vs. Surat (Gujarat). Surat. Pan No. Arxpm 7000 N Appellant/ Assessee Respondent/ Revenue

Section 115BSection 254(1)Section 68

31/03/2016. The assessee furnished list of persons/labourers to whom the money was advanced. The amount paid in advance to labourers were from accumulation of income earned from year to year and it was not income of A.Y. 2016-17. The objection of Assessing Officer was that the advance

Shri Kbl Sharma Memorial Educational & Cultural Society, Defence Public School, E-Block, Amrapali Circle, Vaishali Nagar, Jaipur vs. ITO(Exemption), Ward-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 251/JPR/2023[2012-13]Status: DisposedITAT Jaipur14 Jun 2023AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. MonishaChoudhary, Addl. CIT-DR

Section 11(2)Section 12ASection 154

JAIPUR 2. The ld. CIT(A), NFAC has erred on fact and in law in not deciding the ground relating to not allowing accumulation of income of Rs.6,65,147/- u/s 11(2) of the Act even when assessee has furnished Form No. 10 for accumulation of income ... basis of material/ record available with him. However, from the records, it can be noted that assessee had moved an application for accumulation of income u/s 11(2) in Form No.10 on 20.09.2012 (PB 10-11). Considering the same, AO in the original assessment order allowed the application of income

Beckhaul Digital Technologies Private Limited, Jaipur vs. ITO Ward 1(1), Jaipur

In the result, all the three appeals of the assessee in ITA No

ITA 97/JPR/2023[2020-21]Status: DisposedITAT Jaipur08 Jun 2023AY 2020-21

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajeev Sogani, CA &For Respondent: Mrs. Runi Pal, Addl. CIT-DR

Section 143(1)Section 143(1)(a)Section 36(1)Section 36(1)(va)

regular assessment, then question that needs to be considered is whether the Assessing Officer can make adjustments towards capital gains and accumulation of income u/s 11(2) of the Income Tax Act, 1961, while processing retum u/s 143(1) of the Act. The provisions of section 143(1) deals with ... writing or electronic mode. In this case, admittedly no such intimation was given to the assessee before making adjustment towards capital gain and accumulation of income u/s.112) of the Income Tax Act, 1961. Therefore, on this count itself adjustment made by the Assessing Officer towards capital gain and accumulation

Smt Dakuben Saremalji Sancheti Nadol Charitable Trust, Mumbai vs. National Faceless Appeal Centre (NFAC), Delhi, Mumbai

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

ITA 3202/MUM/2022[2020-21]Status: DisposedITAT Mumbai31 May 2023AY 2020-21

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant ()

For Appellant: Mr. G.P. MehtaFor Respondent: Mr. P.D. Chougule (Addl. CIT)

Section 143(1)

Form 10 in relation to accumulation of . 10B in Form 10 in relation to accumulation of . 10B in Form 10 in relation to accumulation of income were also not filed by the assessee before the due date of the income were also not filed by the assessee before

ITO(E), Ward- 1(3), New Delhi vs. Centre for Health and Social Justice, Delhi

In the result, the appeal of the revenue is dismissed

ITA 1308/DEL/2022[2019-20]Status: DisposedITAT Delhi29 May 2023AY 2019-20

Bench: Shri Chandra Mohan Garg & Shri M.Balaganeshassessment Year: 2019-20 Ito (E), Ward-1(3), New Delhi Centre For Health & Social Justice, G-Block, Saket, New Delhi 110017 Vs. Pan Aaatc 7866 L

For Appellant: Shri S.K. Chaturvedi, CAFor Respondent: Shri Vipul Kashyap, Sr.DR

Section 11

view that when the assessee has filed return of income on or before due date specified us.139 (4) of the Act and claimed accumulation of income by filing Form No. 10 before completion of assessment, then the A0 should not have rejected exemption claimed by the assessee for accumulation

M/S Board of Examination for Seafarers Trust, Mumbai vs. Ld Assistant Commissioner of Income Tax, Central Circle 5(3), Mumbai

ITA 300/MUM/2023[2019-20]Status: DisposedITAT Mumbai19 May 2023AY 2019-20

Bench: Shri Kuldip Singh & Shri Gagan Goyal

For Appellant: Shri Kartik Natrajan, CAFor Respondent: Shri Chetan M. Kacha, Sr. AR

Section 11(2)Section 12A

definitely not in the contemplation of section 11(2) when it is construed in its setting. The assessee's contention that saving and accumulation of income for future application of the same is for the purposes of the trust in the widest terms so as to embrace the entirety ... that in order to claim exemption u/s 11(2) the trustee should have inter alia specific purpose in mind for which it requires accumulation of income to be spent over a long period; that such specific purpose for which the accumulation is done is to be decided by the trustee

M/S Board of Examination for Seafarers Trust, Mumbai vs. Ld Assistant Commissioner of Income Tax, Central Circle 5(3), Mumbai

ITA 299/MUM/2023[2018-19]Status: DisposedITAT Mumbai19 May 2023AY 2018-19

Bench: Shri Kuldip Singh & Shri Gagan Goyal

For Appellant: Shri Kartik Natrajan, CAFor Respondent: Shri Chetan M. Kacha, Sr. AR

Section 11(2)Section 12A

Xprize Foundation, Mumbai vs. Additional /Joint/Deputy/ACIT/Income Tax Officer, National E-Assessment Centre, Mumbai

In the result, the present appeal is allowed for statistical purposes

ITA 2187/MUM/2022[2018-19]Status: DisposedITAT Mumbai28 Nov 2022AY 2018-19

For Appellant: NoneFor Respondent: Shri R.N. D‟souza

Section 11Section 11(2)Section 139(1)Section 143Section 143(3)

comply with the mandate of filing Form 10 within the prescribed time, the Assessing Officer was correct in denying the benefit of accumulation of income and making addition of INR 67,83,011/- in the hands of the Appellant. ITA. No. 2187/Mum/2022 Assessment Year: 2018-19 9. We have considered

Cancare Trust, Mumbai vs. The Comm of Income Tax (Appeal) NFAC, Mumbai

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

ITA 1155/MUM/2022[2015-16]Status: DisposedITAT Mumbai21 Oct 2022AY 2015-16

Bench: Shri B. R. Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.1155/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2015-16) Cancare Trust बिधम/ The Commissioner Of A-508, Byculla Service Income Tax (Appeals), Vs. Industries Premises Chs, National Faceless Appeal Dadaji Konddev Road Centre, Mumbai. Byculla (E), Mumbai- 400027. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaatm4606L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Mr. Vallabh Gokhale/Ms. Mrunmayee Kajrekar Revenue By: Mr. P. D. Chougule (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 03/10/2022 घोषणा की तारीख /Date Of Pronouncement: 21/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Trust Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), (Nfac), Delhi Dated 23.03.2022 For The Assessment Year 2015-16. 2. The Grounds Of Appeal Raised By The Assessee Are As Under: - “1. The Learned Cit(A) Erred In Including The Total Income Of The Appellant Accumulation U/S 11(2) Of The Act Amounting To Rs.1,20,13,966/- Without Taking Cognizance Of The Form 10 Filed By The Appellant On 29Th Sep, 2015 With The Office Of The Learned Ao. 2. The Learned Cit(A) Erred In Treating Ground No. 1 Of Cit(A) With Respect To Accumulation U/S 11(2) Of The Act As Withdrawn.”

For Appellant: Mr. Vallabh Gokhale/MsFor Respondent: Mr. P. D. Chougule (Sr. AR)

Section 11Section 11(1)(b)Section 11(2)Section 12A

into consideration the Form no. 10 physically submitted as on 29.09.2015 (AY. 2015-16) and take a fresh decision in respect of the accumulation of income as per the section 11(2) of the Act in accordance to law. 5 A.Y. 2015-16 Cancare Trust 5. In the result

DCIT, Chennai vs. The Willingdon Charitable Trust, Chennai

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

ITA 587/CHNY/2015[2011-12]Status: DisposedITAT Chennai14 Oct 2022AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.587/Chny/2015 िनधा"रण वष"/Assessment Year: 2011-12 The Deputy Commissioner Of Vs. M/S. The Willingdon Charitable Trust, Income Tax (Exemptions), Chennai Rani Seethai Hall, No. 603, Anna Salai, Circle, Aayakar Bhavan, Annexe Chennai 600 006. Building, Iii Floor, 121, M.G. Road, Nungambakkam, Chennai 600 034. [Pan:Aaatt0683N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Hema Bhupal, Jcit ""थ" की ओर से/Respondent By : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 03.08.2022 घोषणा की तारीख /Date Of Pronouncement : 14.10.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai, Dated 12.12.2014 Relevant To The Assessment Year 2011-12. The Revenue Has Raised The Following Grounds: Ground No.1 1. The Order Of The Learned Cit (A) Is Contrary To The Law & Facts Of The Case. Ground No:2: 2.1 The Id Cit(A) Erred In Holding That The Assessee Is Eligible For Exemption U/S 11 Of The Act & Not Hit By The Amended Provisions Of Sec.2(15) Of The Act, Under The Object Of "General Public Utility".

For Appellant: Shri D. Hema Bhupal, JCITFor Respondent: Shri S. Sridhar, Advocate

Section 11Section 2(15)

held that the assessee is not entitled for claiming exemption under sections 11 of the Act. 6.5 So far as accumulation of income in the assessment year 2011- 12 is concerned, the assessee has not filed Form No. 10. Therefore, it has to be taxed under the year under consideration

Maharashtra Housing & Area Development Authority, Mumbai vs. Asst CIT (E) 2(1), Mumbai

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

ITA 5597/MUM/2017[2013-14]Status: DisposedITAT Mumbai12 Oct 2022AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.5597/Mum/2017 (निर्धारण वर्ा / Assessment Year: 2013-14) Maharashtra Housing & Acit (Exemption)-2(1) बिधम/ Area Development Piramal Chambers, Vs. Office Of Finance Lalbaug, Mumbai- Controller, Mhada, 4Th 400012. Floor, Griha Nirman Bhavan, Kala Nagar, Bandra (E), Mumbai- 400051. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaajm0344H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Nishant Thakkar/Ms. Jasmine Amalsadvala Revenue By: Shri S. H. Usmani (Dr) सुनवाई की तारीख / Date Of Hearing: 19/09/2022 घोषणा की तारीख /Date Of Pronouncement: 12/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-01, Mumbai Dated 28.06.2017 For Assessment Year 2013-14. 2. The Grounds Of Appeal Preferred By Assessee Are As Under: - “1.0 Denial Of Exemption Under S. 11 The Learned Cit(A) Erred On Facts & Circumstances Of The Case & In Law In Upholding The Assessment Order Appealed Against Denying Exemption Under S.11 Of The Act. Relief Claimed: The Appellant Be Granted Exemption Under S.11 Of The Act. 2.0 Engaged In Business:

For Appellant: Shri Nishant Thakkar/Ms. JasmineFor Respondent: Shri S. H. Usmani (DR)

Section 11(1)(a)Section 11(2)Section 234B

w.r.t Rs 7,24,74,44,615/- or to the amount as may be determined. 7.0 Form No.10 for accumulation of income u/s 11(2) of the Act not considered The learned CIT(A) erred on facts and in law in confirming action of the Assessing Officer disregarding the application ... made in Form No 10 for accumulation of income U/s 11(2) of the Act. Relief claimed: Application made in Form 10 as filed by the Appellant be considered. 8.0 Levy of Interest u/s 234B & 234C The learned CIT(A) erred in law and on facts in confirming the dismissing

Rajiv Gandhi University of Health Sciences, Bangalore vs. The Deputy Commissioner of Income Tax, CPC, Bangalore

In the result, the appeal filed by the assessee in ITA No

ITA 584/BANG/2022[2016-17]Status: DisposedITAT Bangalore29 Sept 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Mrs. Suman Lunkar, CAFor Respondent: Smt. S. Praveena, CIT DR

Section 10Section 10(23)(C)Section 11(2)Section 11(5)Section 12ASection 143(2)Section 154Section 234B

total income of the organisation if the following conditions are applied.  Such trust or institution furnishes Form No 10 — notice of accumulation of income by charitable trust or institution electronically to assessing officer, on or before the due date for filing the R/I.  Mention the purpose for which income ... either during the period of accumulation or thereafter.] The conditions specified are that the taxpayer applies to the assessing officer the purpose for accumulation of income as well as the period of accumulation and that the money so accumulated or set apart is invested in the deposits specified

Rajiv Gandhi University of Health Sciences, Bangalore vs. The Deputy Commissioner of Income Tax, CPC, Bangalore

In the result, the appeal filed by the assessee in ITA No

ITA 563/BANG/2022[2016-17]Status: DisposedITAT Bangalore29 Sept 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Mrs. Suman Lunkar, CAFor Respondent: Smt. S. Praveena, CIT DR

Section 10Section 10(23)(C)Section 11(2)Section 11(5)Section 12ASection 143(2)Section 154Section 234B