Held that sub-section (7) inserted in section 11 vide Finance (No.2) Act, 2014, whereby it has been provided that benefits of exemption provided in section 10 shall not be available to any trust/institution registered and claiming benefit of section 11 was brought with effect from 1-4-2015, therefore, is only applicable to assessment year 2015-16 and onwards. Therefore, even though assessee’s entire income derived from property held under trust was governed by provision of section 11, assessee could not be denied benefit of exemption under section 10(34) in respect of dividend income received by it during assessment years 2011-12 to 2014-15 of the Act. (AY. 2011-12 to 2014-15)
ACIT v. Navajibhai Ratan Trust (2022) 213 DTR 25 / 217 TTJ 137 / 140 taxmann.com 157 (Mum)(Trib)
S. 11 : Property held for charitable purposes-Exemption of income from property-Sub-section (7) inserted in section 11 vide Finance (No.2) Act, 2014, providing that benefits of exemption provided in section 10 shall not be available to any Trust/Institution registered and claiming benefit of section 11 was brought with effect from 1-4-2015, therefore, is only applicable to assessment year 2015-16 and onwards. [S. 10(34), 11(7)]