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2024 Supreme(Online)(ITAT) 1956

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
Shri Siddhartha Nautiyal, J, Shri Makarand V. Mahadekar, ACJ
Parul Arogya Seva Mandal Trust – Appellant
Versus
Revenue – Respondent


Advocates:
For the Appellants/Petitioners: Shri Samir Parikh
For the Respondents: Shri Sudhendu Das

Table of Content
1. background of the assessee trust. (Para 1 , 2)
2. assessee's defense regarding financial operations. (Para 3 , 5)
3. legal framework regarding sections 11 and 13. (Para 7)
4. consequential judgment of appeals. (Para 8)

आदेश/ORDER

PER BENCH:

Out of these five appeals, two appeals being ITA Nos.991 & 992/Ahd/2023 filed by the assessee, namely, Parul Arogya Seva Mandal Trust and ITA No.993/Ahd/2023 filed by the assessee namely, Parul University for Assessment Years (AYs) 2016-17, 2017-18 & 2017-18 respectively and ITA Nos.1018 & 1019/Ahd/2023 filed by the Revenue for AYs 2016-17 & 2017-18 are directed against the separate orders of Ld. Commissioner of Income-tax (Appeals)-11, Ahmedabad [Ld. CIT(A)] all dated 22/09/2023. Since these appeals filed in the case of assessees belonging to the same group, involve common issues, the same have been heard together and are being disposed of by a single consolidated order for the sake of convenience.

Facts of the case

2. The assessee Trust is a public charitable Trust with main aim is to provide education in Diploma Engineering all disciplines; to achieve this objects the assessee Trust is running various colleges in the name as

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