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

xii) of Section 11 (5), after 30th November 1983. None of these conditions are satisfied in the present case. However, proviso to Section 13(1) (d) states that nothing in the clause, containing aforesaid provision, will apply to, inter alia, “ (i) any assets held by the trust or institution where such assets form part of the corpus of the trust

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

trust. The Ld. CIT(A) in view of decision of the Hon’ble Kerala High Court decision of the Hon’ble Kerala High Court(supra), which which has been further affirmed by the Hon’ble Apex Court further affirmed by the Hon’ble Apex Court, rejected the contention rejected the contention of the Assessing Officer. Further

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

In the result, the appeal is allowed

xii) of Section 11 (5), after 30th November 1983. None of these conditions are satisfied in the present case. However, proviso to Section 13(1) (d) states that nothing in the clause, containing aforesaid provision, will apply to, inter alia, “ (i) any assets held by the trust or institution where such assets form part of the corpus of the trust

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

In the result, the appeal is allowed

xii) of Section 11 (5), after 30th November 1983. None of these conditions are satisfied in the present case. However, proviso to Section 13(1) (d) states that nothing in the clause, containing aforesaid provision, will apply to, inter alia, “ (i) any assets held by the trust or institution where such assets form part of the corpus of the trust

INCOME TAX OFFICER-23(1)(2), MUMBAI vs. INDIAN CORPORATE LOAN SECURITIES TRUST 2008 SERIES 14, MUMBAI

In the result, Revenue's appeal for A

Bench: Shri M.Balaganesh, Am & Shri Ravish Sood, Jm The Ito-23(1)(2) Vs. M/S. Indian Corporate Loan Room No.18 Securities Trust 2008 Matru Mandir Series 14 Grant Road Il & Fs Financial Centre Mumbai – 400 007 Plot No.C-22, G Block 3Rd Floor, Bandra Kurla Complex, Bandra East Mumbai – 400 051 Pan/Gir No. Aaat16786P (Appellant) .. (Respondent) The Ito-23(1)(2) Vs. M/S. Indian Corporate Loan Room No.18 Securities Trust Series Iii Matru Mandir 2009 Grant Road Il & Fs Financial Centre Mumbai – 400 007 Plot No.C-22, G Block Bandra Kurla Complex, Bandra East Mumbai – 400 051 Pan/Gir No. Aaat17440L (Appellant) .. (Respondent) The Ito-23(1)(2) Vs. M/S. Indian Corporate Loan Room No.18 Securities Trust Series Matru Mandir 2008 Series 36 Grant Road Il & Fs Financial Centre Mumbai – 400 007 Plot No.C-22, G Block Bandra Kurla Complex, Bandra East Mumbai – 400 051 Pan/Gir No. Aaat16925L (Appellant) .. (Respondent) आदेश / O R D E R Per Bench: These Appeals In Ita No.4789/Mum/2017, 4791/Mum/2017 & 4794/Mum/2017 For A.Y.2010-11 Arise Out Of The Order By The Ld. Commissioner Of Income Tax (Appeals)-32, Mumbai In Appeal No.Cit(A)- 32/It-604/23(1)(2)/2015-16, Cit(A)-32/It-48/19(3)(2)/2012-13 & Cit(A)-32/It-483/Ito-19(3)(4)/12-13 Respectively Dated 24/04/2017 (Ld. Cit(A) In Short) Against The Order Of Assessment Passed U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As Act) Dated 26/02/2016, 31/10/2012 Respectively By The Ld. Income Tax Officer – 23(1)(2) & 19(3)(2) Respectively, Mumbai (Hereinafter Referred To As Ld. Ao).

36 Grant Road IL & FS Financial Centre Mumbai – 400 007 Plot No.C-22, G Block Bandra Kurla Complex, Bandra East Mumbai – 400 051 PAN/GIR No. AAAT16925L (Appellant) .. (Respondent) आदेश / O R D E R PER BENCH: These appeals in ITA No.4789/Mum/2017, 4791/Mum/2017 & 4794/Mum/2017 for A.Y.2010-11 arise out of the order by the ld. Commissioner of Income Tax (Appeals)-32, Mumbai

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CENT. CIR.1(4), MUMBAI vs. PODAR EDUCATION & SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CIR 1(4) , MUMBAI vs. PODAR EDUCATION & SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CENT. CIR 1(40, MUMBAI vs. PODAR EDUCATION AND SPORTS TRUSTS, BENGALURU

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CENT. CIR1(4) , MUMBAI vs. PODAR EDUCATION & SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CIR1(4) , MUMBAI vs. PODAR EDUCATION AND SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CIR 1(4) , MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CENT. CIR 1(4) , MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

xii. financial statement of the assessee’s trust shows that it has given a donation of ₹1,25,00,000/- towards education purposes as submitted in administrative expenses schedule 7 of the annual accounts. Assessee trust has shown fees income of ₹30.81 crores and has excess of ₹5,20,00,000/- for this year and none of the examination

ITO 19(3)(2), MUMBAI vs. INDIAN CORPORATE LOAN SECURITIZATION TRUST 2008 SERIES 14I, MUMBAI

In the result, Revenue’s appeal for A

Bench: Shri Jason P. Boaz & Shri Sandeep Goasinindian Corporate Loan Securitisation Income Tax Officer-9(3)(2) Trust- 2008 Series 14 Mumbai C/O. Il & Fs Trust Co. Ltd. Vs. 10Th Floor, “G” Block, Bkc Bandra (E), Mumbai 400051 Pan – Aaati6786P Appellant Respondent Income Tax Officer-(23)1)(2) Indian Corporate Loan [Erstwhile Ito-19(3)(2)] Securitisation Trust- 2008 Series 14 Room No. 108, Matru Mandir Vs. C/O. Il & Fs Trust Co. Ltd. Tardeo Road, Grant Road 10Th Floor, “G” Block, Bkc Mumbai 400007 Bandra (E), Mumbai 400051 Pan – Aaati6786P Appellant Respondent

XII-EA of the Income Tax Act, 1961, inserted by Finance Act, 2013 provides that for securitization of loan by a trust the SPV has been defined in explanation clause (d) to section 115TC of the Act. That there has been a securitization by Yes Bank of the loan advanced to HPCL is not disputed. (iii) Revenue accepts that

SIR RATAN TATA TRUST,MUMBAI vs. CIT (EXEMPTION), MUMBAI

Bench: Shri G. S. Pannu & Shri Vikas Awasthyआअसं. 773/मुं/2021 (िन.व.2016-17) Sir Ratan Tata Trust, Bombay House, 24, Homi Modi Street, Fort, Mumbai-400001. Pan: Aaats1013P ...... अपीलाथ" /Appellant बनाम Vs. Cit (Exemptions), Room No.617, 6Th Floor, Piramal Chambers, Lalbaug, Parel, Mumbai-400012 ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Sh. Sukhsagar Syal, Advocate "ितवादी "ारा/Respondent By : Sh. Amol Kirtane, Cit-Dr सुनवाई की ितिथ/ Date Of Hearing : 15/12/2021 घोषणा की ितिथ/ Date Of Pronouncement : 16/02/2022 आदेश/ Order

xii) of Section 11 (5), after 30th November 1983. None of these conditions are satisfied in the present case. However, proviso to Section 13(1) (d) states that nothing in the clause, containing aforesaid provision, will apply to, inter alia, " (i) any assets held by the trust or institution where such assets form part of the corpus of the trust

MAHANSARIA ENTERPRISES PVT LTD,MUMBAI vs. PR. CIT, MUMBAI-5, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2020-21 Mahansaria Enterprises Private The Principal Commissioner Of Limited, Income Tax (Pcit), 301-304, 3Rd Floor, Vs. Room No. 515, 5Th Floor, Peninsula Chambers, Aayakar Bhavan, Peninsula Corporate Park, Maharshi Karve Road, G.K. Marg, Lower Parel West, Mumbai-400020 Mumbai-400026 Pan : Aaacy1568L (Appellant) (Respondent) For Assessee : Shri Vipul Joshi, Adv. & Prashant Bhumare For Revenue : Shri Satyaprakash R. Singh, Cit-Dr Date Of Hearing : 14-05-2025 Date Of Pronouncement : 11-06-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax, Mumbai-5 [„Ld.Pcit‟] U/S. 263 Of The Income Tax Act, 1961 („The Act‟), Dated 17-03-2025, Pertaining To Assessment Year (Ay) 2020-21, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

xii. American Express (India) P. Ltd. vs. PCIT [2024] 166 taxmann.com 91 (Delhi-Trib.) 12 xiii. Interglobe Technology Quotient (P.) Ltd. vs. ACIT [2024] 163 taxmann.com 542 (Delhi-Trib.) 13. Per contra, the Ld. DR relied on the findings of the Ld.PCIT. The ld PCIT has referred to the explanation 2 to Section 37(1) of the Act, the explanatory