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Royal Credit Co-Operative Society ... vs A.O., Nfac, Delhi/Income Tax Officer ... on 20 June, 2023

221/JPR/2023 may be taken as a lead case for discussions as the issues involved in the lead case are common and inextricably interlinked or in fact interwoven and the facts and circumstances of other cases are identical except the difference in the amount in other assessment year. The ld. DR did not raise any specific objection against taking that case as a lead case. Therefore, for the purpose of the present discussions, the case of ITA No. 221/JPR/2023 is taken as a lead. Based on the above arguments we have also seen that for both these appeals are similar facts, similar arguments and similar grounds raised, therefore, were heard together these two appeals and are disposed by taking lead case facts, grounds and arguments from the folder in ITA No. 221/JPR/2023 for the assessment year 2018-19 and the order 3 ITA Nos. 221 & 222/JP/2023 Royal Credit Co-operative Society Ltd vs. AO there in passed shall mutatis mutandis apply to the ITA No. 222/JPR/2023.
Income Tax Appellate Tribunal - Jaipur Cites 53 - Cited by 0 - Full Document

Delhi E-Governance Society,New Delhi vs Assessing Officer, Delhi on 18 February, 2026

5. That the Ld. CIT(A) further erred in upholding the disallowance of accumulation of income u/s 11(2) amounting to ₹3,33,71,275/- and the application of income towards charitable Page 2 of 5 5874/DEL/2025(AY 2019-20) Delhi e-Governance Society vs AO purposes amounting to 2,29,89,296/-, despite the fact that the appellant had duly complied with the conditions prescribed u/s 11(5) of the Act. It is a settled principle that what can be brought to tax is only the surplus, if any, after application and permissible accumulation of income, and not the gross receipts themselves. The action of treating gross receipts as taxable runs contrary to the scheme and intent of sections 11 to 13 of the Income-tax Act, 1961.
Income Tax Appellate Tribunal - Delhi Cites 8 - Cited by 0 - Full Document
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