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    <title>1985 (7) TMI 152 - ITAT DELHI-A</title>
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    <description>A trust&#039;s exemption under section 11 was examined in the context of section 13(3)(b) where the tenant company fell within the related-party threshold. The decisive question was whether the rent for property let long before the relevant contribution was inadequate. Rent control restrictions, municipal valuation, fair-rent principles, agreed rental value, and the tenant&#039;s responsibility for repairs and municipal tax supported adequacy. Material suggesting a higher rent was not confronted to the assessee and could not be relied on against it. On the facts, the rent was not shown to be sham, collusive, or so low as to amount to use of trust property for the contributor&#039;s benefit, so revision under section 263 and denial of exemption were not justified.</description>
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    <pubDate>Tue, 30 Jul 1985 00:00:00 +0530</pubDate>
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      <title>1985 (7) TMI 152 - ITAT DELHI-A</title>
      <link>https://www.taxtmi.com/caselaws?id=62957</link>
      <description>A trust&#039;s exemption under section 11 was examined in the context of section 13(3)(b) where the tenant company fell within the related-party threshold. The decisive question was whether the rent for property let long before the relevant contribution was inadequate. Rent control restrictions, municipal valuation, fair-rent principles, agreed rental value, and the tenant&#039;s responsibility for repairs and municipal tax supported adequacy. Material suggesting a higher rent was not confronted to the assessee and could not be relied on against it. On the facts, the rent was not shown to be sham, collusive, or so low as to amount to use of trust property for the contributor&#039;s benefit, so revision under section 263 and denial of exemption were not justified.</description>
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      <pubDate>Tue, 30 Jul 1985 00:00:00 +0530</pubDate>
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