AKSHAY EDUCATIONAL & SOCIAL WELFARE CHARITABLE TRUST,BODHGAYA vs. DCIT, CIRCLE-3, GAYA
In the result, the appeal of the assessee is hereby dismissed
ITA 3/PAT/2017[2011-12]Status: DisposedITAT Patna11 Jan 2023AY 2011-12
Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. No.03/Pat/2017 Assessment Year: 2011-12 Akshay Educational & Social Welfare Charitable Trust............……….……Appellant Amawa (Thakar), Bodhgaya-824234. [Pan:Aacta5613R] Vs. Dcit, Circle-3, Gaya….....………............…............……........……...…..…..Respondent Appearances By: Shri A.K. Rastogi, Sr. Adv. & Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 21, 2022 Date Of Pronouncing The Order : January 11, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.08.2016 Of The Commissioner Of Income Tax (Appeals)-1, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:
Section 11Section 12ASection 250
108 dated 20-3-1973 is extracted at page 1277 of Vol. I of Sampat Iyengar's Law of Income-tax, 9th Edn. in which the inter-relation between section 12 and section 2(24)(iia) has been brought out. Gifts made with clear directions that they shall form part of the corpus of the religious endowment can never