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2019 (5) TMI 1064 - HC - Income TaxExemption u/s 11 - interest-free loan advanced to other charitable trusts RKSCT - violation of Section 13(3) - CIT (A) who held that RKSCT was itself registered u/s 12A and that the advancing of a loan by one charitable trust to another should be treated as application of income towards the objects of the trust - ITAT held that this advancing of loan to another trust did not violate either Section 13(1)(c) or 13(2)(g) - HELD THAT:- The issue appears to be no longer res integra. In CIT v. Shri Ram Memorial Foundation [2004 (5) TMI 44 - DELHI HIGH COURT] the donation of income to another charitable trust was held to be in consonance with the objects of the trust. Subsequently, in Director of Income-Tax v. ACME Educational Society [2010 (7) TMI 159 - DELHI HIGH COURT] this Court again upheld the advancing of a loan by one charitable trust to the other. The Court referred to an earlier decision of Director of Income-Tax v. Pariwar Sewa Sansthan [2001 (5) TMI 13 - DELHI HIGH COURT] in this regard. In view of the decision in Director of Income Tax (Exemption) v. Bagri Foundation [2010 (7) TMI 85 - DELHI HIGH COURT] which has considered the above explanation to Section 11(2) of the Act the Court, the Court finds that no substantial question of law arises in this appeal.
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