Assistant Commissioner Of ... vs Sinhagad Technical Education ... on 17 October, 2018
6.12 The next contention of the appellant is that Shri M.N.Navale
was making immense contribution to the management of the affairs of
the appellant trust including day to day administration, coordination
and liaison, obtaining necessary clearances from government
authorities, entering into agreements, pursuing legal matters,
managing the financial affairs, acquiring properties, arranging
finance, standing guarantee for loans etc. As such he was
shouldering tremendous responsibilities the value of which would not
be less than Rs. 4,00,000/- per month and these had to be
considered even by very conservative standards. Considering these
facts, the benefit accruing to him by way of rent was very meager.
The decision of the Hon'ble Madras High Court In CIT vs. Society of
Immaculate Conception 241 ITR 193, is relied upon. This issue too
was considered by CIT(A)-II, Pune while deciding the appellant's case
for AY 2006-07. Having considered the argument, the Ld. CIT(A)
observed as follows: