DCIT v. CMR Jnanadhara Trust. (2025) 210 ITD 519 (Bang) (Trib.)

S. 13 : Denial of exemption-Trust or institution-Investment restrictions-Own case for earlier assessment years, exemption under section 11 was allowed-No change of facts-Exemption is allowed. [S.11, 13(1)(c)]

Assessee-trust, engaged in educational activities, filed its return of income declaring nil income after claiming exemption under section 11. Assessing Officer held that  the  assessee had made certain payments to specified persons and, thus, had extended benefits to specified persons and, consequently, provisions of section 13(1)(c) had been violated hence  he denied exemption. CIT(A) allowed the claim. On appeal the Tribunal affirmed the order of the CIT(A).(AY. 2017-18,2018-19, 2021-22)

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