PCIT v. Sinhagad Technical Education Society (2025)472 ITR 15 (Bom)(HC) Editorial: PCIT v. Sinhagad Technical Education Society (2025)472 ITR 18 (SC), High Court is directed to consider second question of law along with other questions admitted.

S. 13 : Denial of exemption-Trust or institution-Investment restrictions- Tribunal right in holding that disqualification would apply only to that part of income which was in violation of conditions-No substantial question of law- Circular No. 387 Dated 6-7-1984 (1985) 152 ITR 1 (St)- Search and seizure- Documents found in the course of search- Question of law admitted. [S. 13(1)(c), 260A].

Held that the court declined to admit the appeal on the second question of law on the premise that it was covered by Circular No. 387 dated July 6, 1984 ([1985] 152 ITR (St.) 1) issued by the Central Board of Direct Taxes, to the effect that where a trust contravenes the provisions of section 13(1)(c) or (d) of the Act, the maximum marginal rate of Income-tax will apply only to that part of the income which had forfeited exemption under the said provisions, but admitted the first question reframed as “whether the Tribunal was right in deleting the addition of Rs. 22,45,06,500 that was added by the Assessing Officer relying on documents found during the search at the residence of the principal trustee of the respondent-society”.

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