Section 40(a)(ia) not applicable to charitable or religious trust before 01.04.2019

Pediatric Infectious Diseases Academy Vs ITO (ITAT Kolkata) Ld. CIT(A) is also not justified in holding that the fact of the assessee being the charitable organisation is of no relevance for the applicability of section 40(a)(ia). As pointed out by the learned counsel for the assessee, this view taken by the Ld. CIT(A) is contrary to the decision of the Hon’ble Bombay High Court in the case of Bombay Stock Exchange vs DDIT 365 ITR 181 wherein it was held that where the income of the assessee was exempt under section 11 and the assessee was not carried on the business, section 40(a)(ia) had ...