PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S.E CITY PROJECTS LUCKNOW (P) LD.
The appeals are dismissed and substantial questions
ITA/85/2018HC Orissa05 Jul 2022
Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE R.K.PATTANAIK
For Appellant: Mr. Tilak Mitra, AdvFor Respondent: Mr. J. P. Khaitan, Senior Adv
Section 11ASection 12ASection 260ASection 3Section 4
6
that the donee trust kept the donated amount in the corpus fund
and the donee trust again issued donation to another charitable
trust from its current income. Therefore, the assessee pointed
out that there is no basis for holding the theory of circular
donation and ultimate receipt of the donation by the donor trust.
Further it was pointed
