SETH WALCHAND HIRACHAND MEMORIAL TRUST,MUMBAI vs. ITO (E) II(1), MUMBAI

In the result, the appeal filed by the assessee is hereby ordered to be Allowed

Bench: Shri D. Karunakara Rao, Am & Shri Amarjit Singh, 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

ASST CIT (E) I(1),MUMBAI vs. JAMSHETJEE TATA TRUST, MUMBAI

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

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

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

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

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

Section 11 (1)(a) are very clear and provide that income derived from property held under trust should not be included in income to extent it was applied for charitable or religious purposes (expenses incurred during the year) or accumulated/set apart to-be applied for that purpose in future out of 75% to which restriction u/s. 11(5) applied—ITAT

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

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

Section 11 (1)(a) are very clear and provide that income derived from property held under trust should not be included in income to extent it was applied for charitable or religious purposes (expenses incurred during the year) or accumulated/set apart to-be applied for that purpose in future out of 75% to which restriction u/s. 11(5) applied—ITAT

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

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

Section 11 (1)(a) are very clear and provide that income derived from property held under trust should not be included in income to extent it was applied for charitable or religious purposes (expenses incurred during the year) or accumulated/set apart to-be applied for that purpose in future out of 75% to which restriction u/s. 11(5) applied—ITAT

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

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

Section 11 (1)(a) are very clear and provide that income derived from property held under trust should not be included in income to extent it was applied for charitable or religious purposes (expenses incurred during the year) or accumulated/set apart to-be applied for that purpose in future out of 75% to which restriction u/s. 11(5) applied—ITAT

TATA EDUCATION TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX , MUMBAI

In the result, the appeal is allowed

Section 164 - Charge of tax where share of beneficiaries unknown.\n(2) In the case of relevant income which is derived from property held under trust wholly for charitable

RATAN TATA TRUST,MUMBAI vs. CIT (E), MUMBAI

In the result, the appeal is allowed

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

DCIT (E)- 2(1), MUMBAI vs. J.R.D TATA TRUST , MUMBAI

In the result, the appeal of Revenue is dismissed and that of the assessee is allowed

Bench: Sri Mahavir Singhaayakr Apila Sam./ Ita No. 3082/Mum/2018 (Inaqa-Arna Baya- / Assessment Year 2012-13) J.R.D Tata Trust, The Income Tax Officer, Bombay House, 24, Homi 2(4), Mody Street, Fort, [Now Assessed By The Mumbai-400 001 Deputy Commissioner Of Vs. Income-Tax (Exemptions)- 2(1), Mumbai, Piramal Chambers, Lalbaug, Parel, Mumbai-400 012 .. (P`%Yaqaai- / Respondent) (Apilaaqai- / Appellant) स्थायी लेखा िं./Pan No. Aaatt0165F

164(2). Thus the exemption u/s 11 is available to the assessee Only on the income to the extent the same is derived in conformity of section 11 and applied during the yea' for such purpose of charitable trust

J.R.D. TATA TRUST,MUMBAI vs. ITO (E) - 2(4) (NOW ASSSESSED BY THE DCIT (E) 2(1), MUMBAI

In the result, the appeal of Revenue is dismissed and that of the assessee is allowed

Bench: Sri Mahavir Singhaayakr Apila Sam./ Ita No. 3082/Mum/2018 (Inaqa-Arna Baya- / Assessment Year 2012-13) J.R.D Tata Trust, The Income Tax Officer, Bombay House, 24, Homi 2(4), Mody Street, Fort, [Now Assessed By The Mumbai-400 001 Deputy Commissioner Of Vs. Income-Tax (Exemptions)- 2(1), Mumbai, Piramal Chambers, Lalbaug, Parel, Mumbai-400 012 .. (P`%Yaqaai- / Respondent) (Apilaaqai- / Appellant) स्थायी लेखा िं./Pan No. Aaatt0165F

164(2). Thus the exemption u/s 11 is available to the assessee Only on the income to the extent the same is derived in conformity of section 11 and applied during the yea' for such purpose of charitable trust

PEGASUS PROPERTIES P. LTD.,PUNE vs. DY CIT, CC-2(3), MUMBAI

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

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

Charitable Trust. Accordingly, ground raised by the assessee is partly allowed. 23. Coming to Ground Nos. 14 and 15 which are in respect of Ad-hoc disallowance of advertisement and sales promotion expenses amounting to ₹.9,71,368/-. Ld. Counsel for the assessee filed his submissions in respect of this issue as under: - “Ground

J.R.D TATA TRUST ,MUMBAI vs. CIT (E), MUMBAI

In the result, the appeal is allowed

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

SHREE JAIN SWETAMBER DEHARSHAR UPSHRAYA TRUST,THANE vs. ASST CIT PALGHAR CIRCLE, PALGHAR, PALGHAR

The appeal of the assessee is partly allowed

Bench: Shri Joginder Singh & Shri N.K.Pradhanassessment Year: 2011-12 Shree Jain Swetamber Acit, Palghar Circle, Deharshar Upshraya Trust Palghar बनाम/ C/O. Anoopchandji Karnava, T Vs. Main Road, Dahanu Town Dahanu Road, Dist: Thane ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No.Aaets4024L

164(2) of the Act are not applicable." 3. The brief facts of the case are that the assessee is a religious charitable trust registered under Bombay Public Trust Act, 1950 engaged in providing stay facilities to sadhus and sadhvis , and pooja facilities to Swetamber Jains. During the course of assessment proceedings u/s. 143(3) read with Section

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

Section 2(15), which defines 'charitable purpose', were not brought to the notice of the court and therefore, the said order passed by the court by merely recording its ipse dixit does not help the Revenue in any manner. Further, even Punjab and Haryana High Court in Tribune Trust v. CIT (390 ITR 347) (supra) while distinguishing the decision

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

Section 2(15), which defines 'charitable purpose', were not brought to the notice of the court and therefore, the said order passed by the court by merely recording its ipse dixit does not help the Revenue in any manner. Further, even Punjab and Haryana High Court in Tribune Trust v. CIT (390 ITR 347) (supra) while distinguishing the decision

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

Section 2(15), which defines 'charitable purpose', were not brought to the notice of the court and therefore, the said order passed by the court by merely recording its ipse dixit does not help the Revenue in any manner. Further, even Punjab and Haryana High Court in Tribune Trust v. CIT (390 ITR 347) (supra) while distinguishing the decision

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

Section 2(15), which defines 'charitable purpose', were not brought to the notice of the court and therefore, the said order passed by the court by merely recording its ipse dixit does not help the Revenue in any manner. Further, even Punjab and Haryana High Court in Tribune Trust v. CIT (390 ITR 347) (supra) while distinguishing the decision