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Commissioner Of Income Tax Amritsar vs Tattan Trust Amritsar Etc on 8 July, 1997

In Rattan Trust (6 Supra) cited by the Revenue, the Supreme Court considered the effect of amendments to Section 13 of the Act and Section 21 A of the Wealth Tax Act,1957 by the Finance Act,1970 w.e.f.1.4.1971. The provisos thereto laid down that exemption under Section 11 will not be denied if part of income or property of the trust or institution created before 1.4.1962, is applied for benefit of a person referred to in sub-section (3) of section 13 of the Act, if such use or application is in compliance with mandatory terms of the trust. In that case, there was no such provision in the trust deed dt.28.3.1942 of the assessee but was sought to be introduced by way of amendment to the trust deed dt.14.3.1971 i.e after 1.4.1962 invoking a clause in the trust deed authorizing making of amendments to the trust deed. The Court said that such a mandate in the trust deed should have existed before 1.4.1962 and could not have been brought in by amending the trust deed at a later stage after that crucial date, even if the trust deed so authorized the trustees to amend the trust deed to bring in the mandatory condition or requirement for them to invest funds of the trust in a concern in which they might be interested. It held that any other interpretation would set at naught the proviso and would defeat the very purpose for which the proviso was added in Section 13. This case is of no assistance to Revenue. Merely because the assessee was registered by SSSPL to run the school after SSSPL's application for approval was rejected by CBSE, it cannot be said that assessee's payment by way of royalty to SSSPL is prohibited and consequently the assessee deprived of exemption u/Section 11 .
Supreme Court of India Cites 13 - Cited by 14 - D P Wadhwa - Full Document

Pt. Kanahya Lal Punj Charitable Trust vs Director Of Income Tax (Exemption) on 14 May, 2007

34. Muthoottu Charitable Trust (7 supra), Kanahya Lal Punj Charitable Trust (8 Supra) and AWARE (9 Supra) cited by the Revenue were decided on the facts noted therein that activities of the respective assessee trusts' were carried on in violation of provisions of Section 13. We are unable to discern any principle of general application which could be of assistance to Revenue in the present case.
Delhi High Court Cites 10 - Cited by 8 - V B Gupta - Full Document

Action For Welfare Awakening In Rural ... vs Deputy Commissioner Of Income Tax on 28 March, 2003

34. Muthoottu Charitable Trust (7 supra), Kanahya Lal Punj Charitable Trust (8 Supra) and AWARE (9 Supra) cited by the Revenue were decided on the facts noted therein that activities of the respective assessee trusts' were carried on in violation of provisions of Section 13. We are unable to discern any principle of general application which could be of assistance to Revenue in the present case.
Andhra HC (Pre-Telangana) Cites 14 - Cited by 12 - B S Reddy - Full Document
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