2023 (9) TMI 404

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... ORDER PER R.S. SYAL, VP : This appeal by the Revenue is directed against the order passed by the Commissioner of income-tax (Central), Pune on 31-10-2014 in relation to the assessment year 2007-08. 2. It is a recalled matter for a fresh disposal of Ground No.6 taken by the Revenue. The earlier order passed by the bench on 17-10-2018 was subsequently recalled vide order dt.12-07-2023 i....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....506/- Shri Yeshwantrao Chavan Shikshan Prasarak Mandal - Rs. 17,25,000/- Shrinath Shikshan Prasarak Mandal - Rs. 8,00,000/- 5. The Assessing Officer (AO) observed that the trustees of the assessee-trust were trustees in two of these three trusts, viz., Savitribai Phule Shikshan Prasarak Mandal and Shrinath Shikshan Prasarak Mandal. He, therefore, held the advancing of loans as a case of violati....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....heard the rival submissions and gone through the relevant material on record. It is seen that Ground No.6 of the Revenue's appeal deals with certain amounts paid by the assessee trust to other trusts where the trustees were also interested, which in the opinion of the AO, led to contravention of provisions of section 13(1)(c) of the Act. Relevant discussion has been made by the AO in para 6 of his....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....(c) but ended up without making any specific addition in this regard. Consequently, there was no reason either for the assessee to raise this issue before the ld. CIT(A) or the ld. first appellate authority to pass an order thereon. In view of the fact that the AO did not make any addition on this score, we are satisfied that the ground taken by the assessee before the ld. CIT(A) and consequently ....