DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-1(1), MUMBAI, MUMBAI vs. ALL INDIA GEM AND JEWELLERY DOMESTIC COUNCIL, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16

section 11 to 13 r.w.s. 2(15) and come to a conclusion .w.s. 2(15) and come to a conclusion without invoking principles of mutuality. The Appellant is a charitable without invoking principles of mutuality. The Appellant is a charitable without invoking principles of mutuality. The Appellant is a charitable trust

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX - 2 (3) (1), MUMBAI

2% of average net\nprofits of the preceding three years on Corporate Social\nResponsibility(‘CSR') activity. The AO observed further that the sum\npaid by the assessee could not be considered as a 'donation' for the\npurpose of Section 80G of the Act. The CSR expenditure claimed as\ndeduction u/s 80G was against the intention of law maker. So when

JAN SEVA MANDAL ,MUMBAI vs. INCOME TAX OFFICER EXEMPTION WARD -1(4), MUMBAI

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2023-24 Jan Seva Mandal, Central Processing Centre Income Vinayalaya, Mahakali Caves Tax Deparment, Bengaluru, Vs. Road, Andheri (East), Income Tax Officer Exemption Mumbai-400093. Ward 1(4), Mumbai. 6Th Floor, Mtnl Te Building, Pedder Road, Mumbai-400026. Pan No. Aaatj 4868 K Appellant Respondent

trust. 2. A A sum sum of of Rs.33,00,000/ Rs.33,00,000/- being being amount amount accumulated accumulated or set apart for specific purposes under or set apart for specific purposes under section 11 (2) section 11 (2) read with section 11(5) of the Act. read with section 11(5) of the Act. Jan Seva Mandal

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. ADDITIONAL /JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, NFAC, MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

trust for charitable purposes, which is of the nature referred to in section 11(4A), tax shall be charged on so much of the relevant income as is not exempt under section 11. Section 164(2

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-2(1), MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

trust for charitable purposes, which is of the nature referred to in section 11(4A), tax shall be charged on so much of the relevant income as is not exempt under section 11. Section 164(2

THE UNITED WORLD COLLEGE COMMITTEE (INDIA),MUMBAI vs. ACIT EXEM. CIRCLE 2 MUMBAI, MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2016-17 The United World College Committee Acit Exem., Circle 2, (India), Piramal Chambers, Lal Baug, Vs. Ground Floor, Mahindra Towers, Parel, Worli, Mumbai-400012. Mumbai-400018. Pan No. Aaatt 3774 C Appellant Respondent

charitable purposes of the trust. In view of the above discussion, we hold that the assessee has fulfilled view of the above discussion, we hold that the assessee view of the above discussion, we hold that the assessee the requirement of section 11(2

ITO(E)-1(1), MUMBAI, MUMBAI vs. BHAVITHA FOUNDATION, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22

charitable entity holding the shares received as corpus in compliance with the provisions of section 11(1)(d) read with section in compliance with the provisions of section 11(1)(d) read with section in compliance with the provisions of section 11(1)(d) read with section 13(1)(d) of the Act and the same cannot be treated

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES,MUMBAI vs. DCIT (E) , MUMBAI

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2018-19

charitable activities and (2) that he has invoked proviso to section 2(15) of the Act also. 14. The Ld. A.R. for the assessee challenging the denial of benefit of section 11 & 12 of the Act by invoking the proviso to section 2(15) of the Act contended inter-alia that proviso to section 12 M/s. Credit Guarantee Fund Trust

DY. COMMISSIONER O INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST(SHIRDI), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

11 A.Ys. 2015-16, 2017-18, 2018-19 Shri Sai Baba Sansthan Trust (Shirdi). considered for academic discussion that such expenditure is incurred for religious purpose, whether it will alter the nature and character of the trust from charitable trust to mix purpose trust within the meaning of provisions of the Act? 10. Whether in the facts and circumstances

DY. COMMISSIONER O INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST(SHIRDI), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

11 A.Ys. 2015-16, 2017-18, 2018-19 Shri Sai Baba Sansthan Trust (Shirdi). considered for academic discussion that such expenditure is incurred for religious purpose, whether it will alter the nature and character of the trust from charitable trust to mix purpose trust within the meaning of provisions of the Act? 10. Whether in the facts and circumstances

SHREE SAI BABA SANSTHAN TRUST (SHIRDI),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX (EXEMPTION) 2(1), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

11 A.Ys. 2015-16, 2017-18, 2018-19 Shri Sai Baba Sansthan Trust (Shirdi). considered for academic discussion that such expenditure is incurred for religious purpose, whether it will alter the nature and character of the trust from charitable trust to mix purpose trust within the meaning of provisions of the Act? 10. Whether in the facts and circumstances

DY. COMMISSIONER OF INCOME TAX (EXEMPTION) 2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST (SHIRDI), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

11 A.Ys. 2015-16, 2017-18, 2018-19 Shri Sai Baba Sansthan Trust (Shirdi). considered for academic discussion that such expenditure is incurred for religious purpose, whether it will alter the nature and character of the trust from charitable trust to mix purpose trust within the meaning of provisions of the Act? 10. Whether in the facts and circumstances

THE GEM & JEWELLERY EXPORT PROMOTION COUNCIL,MUMBAI vs. ASST CIT (E) RG 2(1), MUMBAI

In the result, all the appeals of the assessee are allowed for 10

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13 & Assessment Year: 2013-14 The Gem & Jewellery Export Acit (Exemptions) Range- Promotion Council, 2(1), Vs. Tower-A, Aw-1010, G Block, 5Th Floor, Room No. 519, Bharat Diamond Bourse, Piramal Chambers, Lalbaug, B.K.C., Bandra East, Mumbai-400012. Mumbai-400051. Pan No. Aaatt 3202 H Appellant Respondent Assessment Year: 2014-15 The Gem & Jewellery Export Dcit (Exemptions) Range- Promotion Council, 2(1), Tower-A, Aw-1010, G Block, Vs. 5Th Floor, Piramal Chambers, Bharat Diamond Bourse, Lalbaug, B.K.C., Bandra East, Mumbai-400012. Mumbai-400051. Pan No. Aaatt 3202 H Appellant Respondent

Section 2(15). indicated by proviso (ii) to Section 2(15). 174. The insertion of Section 13(8)144 , the seventeenth 74. The insertion of Section 13(8)144 , the seventeenth 74. The insertion of Section 13(8)144 , the seventeenth proviso to Section 10(23C) and third proviso to Section proviso to Section 10(23C) and third proviso

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

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

11-12 Furniture Pvt. Ltd as well. In view of the same it is submitted that the provisions Section 13(2) are not applicable to the assessee. In this regard reliance is place on the following case law: George Educational, Medical and Charitable Society Vs. Asst. Director of Income Tax (2002) 80 ITD 619 (Coch) Charitable Trust

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

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

11-12 Furniture Pvt. Ltd as well. In view of the same it is submitted that the provisions Section 13(2) are not applicable to the assessee. In this regard reliance is place on the following case law: George Educational, Medical and Charitable Society Vs. Asst. Director of Income Tax (2002) 80 ITD 619 (Coch) Charitable Trust

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

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

11-12 Furniture Pvt. Ltd as well. In view of the same it is submitted that the provisions Section 13(2) are not applicable to the assessee. In this regard reliance is place on the following case law: George Educational, Medical and Charitable Society Vs. Asst. Director of Income Tax (2002) 80 ITD 619 (Coch) Charitable Trust

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

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

11-12 Furniture Pvt. Ltd as well. In view of the same it is submitted that the provisions Section 13(2) are not applicable to the assessee. In this regard reliance is place on the following case law: George Educational, Medical and Charitable Society Vs. Asst. Director of Income Tax (2002) 80 ITD 619 (Coch) Charitable Trust

DCIT(E)-2(1), MUMBAI vs. NEHRU CENTRE, MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Bledcit (E) – 2(1) V. Nehru Centre Room No. 519, 5Th Floor Discovery Of India Building Piramal Chambers, Lalbaug 13Th Floor, Dr. Annie Besant Road Worli, Mumbai - 400018 Mumbai – 400 012 Pan: Aaatn2536J (Appellant) (Respondent) Assessee By : Shri Dilip Thakkar Department By : Shri Dilipkumar Shah

charitable purpose. 1. We would like to submit that the Supreme Court in the case of ACIT vs Thanti trust 247 ITR 785 (SC) held that “The scope of Sub section (4A) of section 11, as amended since 1992, is more beneficial to trust or institution than the scope of the sub-section before the amendment. As it stands amended

MUMBAI METROPLITAN REGION DEVELOPMENT AUTHORITY,MUMBAI vs. DDIT (E) -1(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

charitable purpose'? c) Whether the amendment to section 2(15) made by the Finance Act 2015 w.e.f. 01/04/2016 would apply retrospectively for the impugned assessment year? d) Whether the activities of the Trust could be held as incidental for the attainment for the object of the Trust and applicability of section 11