2020 (10) TMI 41

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....BLE MR. JUSTICE J. B. PARDIWALA ) 1 Since the substantial questions of law as proposed by the revenue are common in all the captioned tax appeals, those were taken up for hearing analogously and are being disposed of by this common order. 2 For the sake of convenience, the Tax Appeal No.259 of 2020 is treated to be lead appeal. This tax appeal under Section 260A of the Income Tax Act, 1961 is at....

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....e Act?" [B] "Whether on the facts and circumstances of the case and in law, the Appellate Tribunal was justified in allowing the benefit of exemptions u/s. 11 without considering the fact that the assessee is involved in widespread commercial activities in nature of business and the activity of the assessee is covered under first and second proviso to section 2(15) of the Act?" [C] "Whether ....

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....,00,00,000/- u/s.11(2) and accumulation @15% of Rs. 2,48,78,277/- u/s. 11(1)(a) of the Act without appreciating the fact that once the proviso to section 2(15) is applicable, the benefit of section 11 and 12 cannot be allowed further?" 5 We have heard Ms. Mauna Bhatt, learned Senior Standing Counsel appearing for the revenue. We need not adjudicate these appeals on merit as the substantial quest....