AdvertisementJCIT Vs S. M. Sehgal Foundation (ITAT Chandigarh) The Revenue appealed against the order of the Commissioner of Income-tax (Appeals) [CIT(A)], which had allowed the assessee’s appeal by holding that the Assessing Officer was not justified in denying exemption under Sections 11 and 12 of the Income-tax Act, treating the assessee trust as an Association of Persons (AOP), making an addition of ₹10,00,000, and restricting application of income to 85% of the receipts. The Revenue contended that the assessee had earned rental income commercially, paid excessive remuneration to its Chief Exec...