TMI Blog2019 (1) TMI 160X X X X Extracts X X X X X X X X Extracts X X X X ..... f salary, allowance or otherwise to any person referred to in sub-section 3 out of resources of the Trust for services rendered to the Trust and the amount so paid is in excess of what may be reasonably paid for such services. Thus, essential requirement for invoking the said provision is that the amount paid was in excess of what may be reasonably paid for the services. In the present case, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of facts and law. In fact, they arise out of a common impugned judgment of Income Tax Appellate Tribunal ( the Tribunal for short) dated 18.2.2015. These appeals are filed by the Revenue. 2. Following questions have been presented for our consideration : (i) Whether the Tribunal was correct in law by holding that the provision of section 13(1)(c) and 13(2)(c) of the I.T. Act were not attr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d SBC was a partnership firm consisting of three partners who happened to be trustees of the respondent assessee trust. The Assessing Officer was of the opinion that the firm i.e. SBC was a firm covered under Section 13(3)(e) of the Act visaavis Trust. The Assessing Officer thereafter carried out the analysis of the expenditure in connection with the advertisements with a special focus on the pa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Section 13 of the Act can be invoked, if any amount is paid by way of salary, allowance or otherwise to any person referred to in sub-section 3 out of resources of the Trust for services rendered to the Trust and the amount so paid is in excess of what may be reasonably paid for such services. Thus, essential requirement for invoking the said provision is that the amount paid was in excess of wh ..... X X X X Extracts X X X X X X X X Extracts X X X X
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