TaxTMI Login
AI OCR ✕Convert scanned orders, printed notices, PDFs and images into clean, searchable, editable text within seconds. Starting at 2 Credits/page
Try Now →Just a moment...
AI OCR ✕Convert scanned orders, printed notices, PDFs and images into clean, searchable, editable text within seconds. Starting at 2 Credits/page
Try Now →
Press 'Enter' to add multiple search terms. Rules for Better Search
Use comma for multiple locations.
---------------- For section wise search only -----------------
Accuracy Level ~ 90%
of 
Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
Note
Bookmark
Share
Don't have an account? Register Here
of Press 'Enter' after typing page number.
Issues: Whether the salary of Rs. 46,50,000 paid to a specified person (relative of trustee) for AY 2020-21 was excessive so as to attract the bar under section 13(1)(c) read with section 13(2)(c) of the Income-tax Act, 1961 and thereby warrant disallowance and denial of exemption under section 11 of the Income-tax Act, 1961.
Analysis: The appeal concerns repeated adjudication on the same question of reasonableness of remuneration paid to the specified person. The First Appellate Authority for earlier assessment years examined the qualifications, experience, role and responsibilities of the person, and concluded that the remuneration was not excessive. The present Commissioner of Income-Tax (Appeals) relied on those consistent prior appellate findings and applied the same factual appreciation to the year under consideration, noting the person's increased role (including designation as CEO), long experience in the field, and contributions in securing grants and sponsorships. The Tribunal examined the material on record, the successive appellate decisions for earlier years, and the basis for the increased remuneration, and found no illegality or infirmity in the reasoned conclusions recorded by the Commissioner of Income-Tax (Appeals).
Conclusion: The disallowance of Rs. 21,50,000 and denial of exemption under section 11 are not sustainable; the order of the Commissioner of Income-Tax (Appeals) setting aside the assessing officer's disallowance is confirmed and the revenue's appeal is dismissed.
TaxTMI 
TaxTMI 
