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Bombay High Court

Commissioner Of Income Tax ... vs Shree Raj Foundation on 4 August, 2022

Bench: Dhiraj Singh Thakur, Abhay Ahuja

                                                                                        1-itxa-158-2018.doc




                                  IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                                      ORDINARY ORIGINAL CIVIL JURISDICTION

                                        INCOME TAX APPEAL NO. 158 OF 2018

                         Commissioner of Income-tax
                         (Exemption), Mumbai                             .. Appellant
         Digitally             Vs.
         signed by
         SHRADDHA
SHRADDHA KAMLESH
                         Shree Raj Foundation, Mumbai
         TALEKAR
                         (Assessment year 2010-11)                       .... Respondent
KAMLESH
TALEKAR  Date:
         2022.08.05
         11:20:32
         +0530

                                                          ****

                         Mr.Suresh Kumar for appellant.

                         Mr.Madhur Agrawal i/b Mr.Atul K. Jasani for respondent.

                                                 CORAM : DHIRAJ SINGH THAKUR AND
                                                         ABHAY AHUJA, JJ.
                                                 DATE     : 4th AUGUST 2022
                         PC :

1. This appeal fled under section 260A of the Income Tax Act, 1961 ('the Act') challenges the order dated 14 th September 2016 passed by the Income Tax Appellate Tribunal, Mumbai Bench ('ITAT'), whereby the appeal, being Income Tax Appeal No.1242/Mum/2014 fled by the Revenue for the assessment year 2010-11, came to be dismissed.

2. We admit the present appeal on the following substantial question of law :

(i) Whether in the facts and circumstances of the case and in law, the ITAT was justifed in upholding the Order of the Commissioner of Income Tax Shraddha Talekar, PS 1/2 1-itxa-158-2018.doc (Appeals) by relying on the decision in cases of CIT Vs. Indian National Theater Trust 1 and Dr.D.Y. Patil Prathishtan Vs. Department of Income Tax 2 and concluding that granting educational loans to other charitable trusts with similar objects is an application of income under section 11(1) of the Act?

3. Call for record and papers.

4. The appeal be listed for 'fnal hearing' in the week commencing from 10th October 2022, High on Board. [ ABHAY AHUJA, J. ] [ DHIRAJ SINGH THAKUR, J.] 1 (2008)305 ITR (Del.) 2 ITA No.1592/PN/11 Shraddha Talekar, PS 2/2