ALLAHABAD BANK Vs. INCOME TAX OFFICER
INCOME TAX APPELLATE TRIBUNAL
INCOME TAX OFFICER
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D.K.Tyagi, Member (J) -
(1.) THE appeal in ITA No. 1320/Ahd/2011 filed by revenue is directed against the order of Ld. CIT(A) -XXI dated 28/02/2011 and the appeals in ITA Nos. 1190/Ahd/2011 & 2591/Ahd/2012 filed by assessee are directed against the order of Ld. DIT(Exemption) dated 16/03/2011 & CIT(A) -XXI dated 11 -10 -2012 respectively.
(2.) ALL these appeals belong to same assessee and are interrelated therefore these were heard together and are being disposed off by this consolidated order.
First we will take up revenue's appeal in ITA No. 1320/Ahd/2011 A.Y. 2008 -09
Revenue has taken following effective ground: -
1. The Ld. CIT(A) has erred in law and on facts in directing to grant the deduction u/s. 11 of Rs. 10,19,39,409/ - of the I.T. Act.
(3.) BRIEF facts of the case are that assessee -trust runs a school for which it had taken loan of Rs. 9 crore for acquiring a plot of land from AUDA which costed Rs. 6,88,24,676/ -. The contract for construction of the school building was given to Niche Realty Pvt. Ltd. The assessee trust is having only two trustees which are as under: -
(i) Shri Ashish J. Desai, managing trustee is a Pediatric doctor by profession who adventured into the field of education.
(ii) Shri Narendra Koringa, a retired teacher of Govt. School who is based at Rajkot.;
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