ASSISTANT COMMISSIONER OF INCOME TAX, KAUTILYA BHAVAN, BKC, MUMBAI vs. TATA EDUCATION TRUST, MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

House, 24, Homi Vs. Kautilya Bhavan, BKC, Mody Street, Fort, Mumbai-400 051 Mumbai-400001 (Appellant) : (Respondent) PAN NO. AAATT 9835A Appellant by : Shri P.J. Pardiwala a/w Shri Sukhsagar Syal & Shri Atul Suraiya Respondent by : Shri Ritesh Mishra, CIT DR (Appellant) (Respondent) Date of Hearing : 29.09.2025 Date of Pronouncement : 10.10.2025 Per Saktijit Dey, Vice President: Captioned are bunch of nine

TATA EDUCATION TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-CIRCLE 2(1), MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

House, 24, Homi Vs. Kautilya Bhavan, BKC, Mody Street, Fort, Mumbai-400 051 Mumbai-400001 (Appellant) : (Respondent) PAN NO. AAATT 9835A Appellant by : Shri P.J. Pardiwala a/w Shri Sukhsagar Syal & Shri Atul Suraiya Respondent by : Shri Ritesh Mishra, CIT DR (Appellant) (Respondent) Date of Hearing : 29.09.2025 Date of Pronouncement : 10.10.2025 Per Saktijit Dey, Vice President: Captioned are bunch of nine

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

House, 24, National Faceless Assessment Homi Mody Street, Fort, Centre-2(1), Vs. Mumbai-400001 MTNL Tele Building, PAN : AAATS1013P Cumballa Hills, Peddar Road, Mumbai-400026. Appellant) : Respondent) Appellant/Assessee by : Shri P. J. Pardiwala a/w Shri Sukhsagar Syal, AR Revenue/Respondent by : Shri Sanyogita Nagpal, CIT-DR Date of Hearing : 22.07.2024 Date of Pronouncement 26.08.2024 : Per Padmavathy S, AM: 1. These

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

House, 24, National Faceless Assessment Homi Mody Street, Fort, Centre-2(1), Vs. Mumbai-400001 MTNL Tele Building, PAN : AAATS1013P Cumballa Hills, Peddar Road, Mumbai-400026. Appellant) : Respondent) Appellant/Assessee by : Shri P. J. Pardiwala a/w Shri Sukhsagar Syal, AR Revenue/Respondent by : Shri Sanyogita Nagpal, CIT-DR Date of Hearing : 22.07.2024 Date of Pronouncement 26.08.2024 : Per Padmavathy S, AM: 1. These

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

houses in India for residential purposes and which is eligible for deduction purposes and which is eligible for deduction under clause (viii) of under clause (viii) of sub-section (1) of section 36;" section (1) of section 36;" It is pertinent that receipt of shares as corpus donation is in It is pertinent that receipt of shares as corpus donation

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

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

d) has a substantial interest. 2. In this regard it is submitted that the applicability of section 13(2)(b) arises when any property of the trust is made available to specified persons exclusively. If the property is made available to every one irrespective of whether they are specified persons or not, then provisions of section 13

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

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

d) has a substantial interest. 2. In this regard it is submitted that the applicability of section 13(2)(b) arises when any property of the trust is made available to specified persons exclusively. If the property is made available to every one irrespective of whether they are specified persons or not, then provisions of section 13

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

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

d) has a substantial interest. 2. In this regard it is submitted that the applicability of section 13(2)(b) arises when any property of the trust is made available to specified persons exclusively. If the property is made available to every one irrespective of whether they are specified persons or not, then provisions of section 13

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

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

d) has a substantial interest. 2. In this regard it is submitted that the applicability of section 13(2)(b) arises when any property of the trust is made available to specified persons exclusively. If the property is made available to every one irrespective of whether they are specified persons or not, then provisions of section 13

TATA EDUCATION TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEPTION) -CIRCLE 2(1), MUMBAI

In the result, Revenue's appeal is dismissed

House, 24, Homi\nMody Street, Fort,\nMUMBAI-400001\n(Appellant)\nPAN NO. AAATT 9835A\n:\n(Respondent)\nAppellant by\nShri P.J. Pardiwala a/w Shri\nSukhsagar Syal & Shri Atul Suraiya\nRespondent by\nShri Ritesh Mishra, CIT DR\n(Respondent)\nDate of Hearing\nDate of Pronouncement\n:\n29.09.2025\n10.10.2025\n2\nITA Nos.4282,4283,4156,4496,4727,\n4835,4852,4419,4873/MUM/24\nTata Education

TATA EDUCATION TRUST ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE -17(3), MUMBAI

In the result, Revenue's appeal is dismissed

House, 24, Homi\nMody Street, Fort,\nMumbai-400001\n(Appellant)\n(Respondent)\nPAN NO. AAATT 9835A\n\n\nAppellant by\n:\nShri P.J. Pardiwala a/w Shri\nSukhsagar Syal & Shri Atul Suraiya\nRespondent by\n:\nShri Ritesh Mishra, CIT DR\n(Appellant)\n(Respondent)\n\n\nDate of Hearing\n:\n29.09.2025\nDate of Pronouncement\n:\n10.10.2025\n\n\n\nORDER\nPer

NAVJBAI RATAN TATA TRUST,MUMBAI vs. ADDITIONAL DIRECTOR OF INCOME TAX (EXEMPTIONS) RANGE-II(NOW ASSESSED BY THE ASSISTANT COMMISSIONER OF INCOME TAX 17(2)), MUMBAI

In the result, appeal by the Revenue being ITA No

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

House, Homi Mody Street ……………. Respondent Mumbai 400 001 PAN – AAATN0202B Assessee by : Shri Sukhsagar Syal, Advocate Revenue by : Shri Rajesh Damor, CIT DR Date of Hearing – 14.02.2022 Date of Order – 10.03.2022 O R D E R PER BENCH The aforesaid cross appeals have been filed by either parties challenging the orders passed by the Commissioner of Income Tax (Appeals

ASSISTANT COMMISSIONER OF INCOME TAX 17(2)), MUMBAI vs. NAVJBAI RATAN TATA TRUST, MUMBAI

In the result, appeal by the Revenue being ITA No

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

House, Homi Mody Street ……………. Respondent Mumbai 400 001 PAN – AAATN0202B Assessee by : Shri Sukhsagar Syal, Advocate Revenue by : Shri Rajesh Damor, CIT DR Date of Hearing – 14.02.2022 Date of Order – 10.03.2022 O R D E R PER BENCH The aforesaid cross appeals have been filed by either parties challenging the orders passed by the Commissioner of Income Tax (Appeals

NAVJBAI RATAN TATA TRUST,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX 17(2)), MUMBAI

In the result, appeal by the Revenue being ITA No

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

House, Homi Mody Street ……………. Respondent Mumbai 400 001 PAN – AAATN0202B Assessee by : Shri Sukhsagar Syal, Advocate Revenue by : Shri Rajesh Damor, CIT DR Date of Hearing – 14.02.2022 Date of Order – 10.03.2022 O R D E R PER BENCH The aforesaid cross appeals have been filed by either parties challenging the orders passed by the Commissioner of Income Tax (Appeals

ASSISTANT COMMISSIONER OF INCOME TAX 17(2)), MUMBAI vs. NAVJBAI RATAN TATA TRUST, MUMBAI

In the result, appeal by the Revenue being ITA No

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

House, Homi Mody Street ……………. Respondent Mumbai 400 001 PAN – AAATN0202B Assessee by : Shri Sukhsagar Syal, Advocate Revenue by : Shri Rajesh Damor, CIT DR Date of Hearing – 14.02.2022 Date of Order – 10.03.2022 O R D E R PER BENCH The aforesaid cross appeals have been filed by either parties challenging the orders passed by the Commissioner of Income Tax (Appeals

NAVJBAI RATAN TATA TRUST,MUMBAI vs. ADDITIONAL DIRECTOR OF INCOME TAX (EXEMPTIONS) RANGE-II(NOW ASSESSED BY THE ASSISTANT COMMISSIONER OF INCOME TAX 17(2)), MUMBAI

In the result, appeal by the Revenue being ITA No

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

House, Homi Mody Street ……………. Respondent Mumbai 400 001 PAN – AAATN0202B Assessee by : Shri Sukhsagar Syal, Advocate Revenue by : Shri Rajesh Damor, CIT DR Date of Hearing – 14.02.2022 Date of Order – 10.03.2022 O R D E R PER BENCH The aforesaid cross appeals have been filed by either parties challenging the orders passed by the Commissioner of Income Tax (Appeals

NAVJBAI RATAN TATA TRUST,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX 17(2)), MUMBAI

In the result, appeal by the Revenue being ITA No

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

House, Homi Mody Street ……………. Respondent Mumbai 400 001 PAN – AAATN0202B Assessee by : Shri Sukhsagar Syal, Advocate Revenue by : Shri Rajesh Damor, CIT DR Date of Hearing – 14.02.2022 Date of Order – 10.03.2022 O R D E R PER BENCH The aforesaid cross appeals have been filed by either parties challenging the orders passed by the Commissioner of Income Tax (Appeals

ASSISTANT COMMISSIONER OF INCOME TAX 17(2)), MUMBAI vs. NAVJBAI RATAN TATA TRUST, MUMBAI

In the result, appeal by the Revenue being ITA No

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

House, Homi Mody Street ……………. Respondent Mumbai 400 001 PAN – AAATN0202B Assessee by : Shri Sukhsagar Syal, Advocate Revenue by : Shri Rajesh Damor, CIT DR Date of Hearing – 14.02.2022 Date of Order – 10.03.2022 O R D E R PER BENCH The aforesaid cross appeals have been filed by either parties challenging the orders passed by the Commissioner of Income Tax (Appeals