2021 (9) TMI 131

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nt appeal relates to denial of exemption u/s. 11 of the Act to the assessee trust on account of income found to have been applied for the benefit of the related persons, as per the provisions of section 13(1)(c) read with section 13(3) of the Act. The AO found the salary paid to two trustees to be not commensurate with the services rendered by them and accordingly, made disallowance of the same as under: Ms.Mandeep Ahluwalia Pahwa = Rs. 9,00,000/- M/s Sandeep Kaur Ahluwalia = Rs. 6,00,000/- 3. While the salary being paid to Ms. Mandeep Ahluwalia Pahwa was Rs. 15 lacs, the AO found the same to be excessive to the extent of Rs. 9 lacs and disallowed the same, while in the case of Ms. Sandeep Kaur Ahluwalia the entire sala....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....carrier as a Lecturer with Govt. of Punjab at Govt. Women's College, Patiala. This job she resigned after her marriage. 5. That both of them inherited this position in the trust on the passing away of their respective fathers who were the founder trustees and chairman of the trust. In the case of Ms. Mandeep Ahluwalia Pahwa on the passing way of her father Shri Rajinder Singh Ahluwalia in 2004 and in the case of Ms. Sandeep Kaur Ahluwalia on the passing away of her father Shri Gurcharan Singh in 1997. It is also not denied that since then the assessee trust has progressed from strength to strength, having 3300 students and 220 teaching and non-teaching staff at present as compared to 1000 students in 2004 when Ms. Mandeep Ahluwalia P....