2013 (3) TMI 151

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....ent. JUDGMENT Concurrent findings of fact have been recorded by the Commissioner of Income Tax (Appeals), and also, by the Tribunal. It was not urged or contended that the income of the assessee Trust has been used or applied during the relevant assessment year directly or indirectly for the benefit of any person referred to in sub-section (3) of Section 13 of the Income Tax Act, 1961. On the ot....

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....n of any superior court. Further, as has already been held by the Tribunal, rectification of a conveyance in relation to a property is not rectification of the regulation of the Trust. The Trust sought benefits of Sections 11 and 12 of the Income Tax Act in respect of the income derived by it from the property in question. That was purported to be denied by the Assessing Officer applying Section 1....