2019 (1) TMI 160

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....w Mr. Subhash Jadhav, Mr. Rupesh Geete and Mr. Shradha Achliya I/b Parinam Law Associates ORDER P.C. 1. These appeals involve the same assessee and identical questions 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 presen....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....as paid to one M/s. Sri Balaji Creativites ("SBC" for short) towards advertisements in various magazines and souvenirs. The Assessing Officer noticed that said 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 visa....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....he present appeals have been filed. 5. We have heard learned Counsel for the parties and perused the material on record. Clause (c) of sub-section 2 of 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....