Satya Vijay Patel Hindu Dharamshala Trust v. CIT

86 ITR 683High Court1972#9178 most cited
12

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Sections most often in play

Section 12ABSection 11Section 12Section 13(1)(b)Section 2(15)Section 80GSection 11(4A)Section 12A

Issues it is cited on

childsection 2(15)registration under section 12asection 12absection 12asection 12section 11prescribedpersonindiadocumentinterest

Judgments citing Satya Vijay Patel Hindu Dharamshala Trust v. CIT

SHRI SHYAM PANCHAYTI VISHRAM BHAWAN,SIKAR vs. CIT(EXEMPTION), JAIPUR

In the result, the appeal of the assessee is allowed for statistical\npurposes

ITA 679/JPR/2024[NOT APPLICABLE]Status: DisposedITAT Jaipur24 Mar 2025
For Appellant: Shri Phru Bhansal, AdvFor Respondent: Shri P.P. Meena, CIT (Th. VH)
Section 11Section 12Section 12A

…individuals. The expenses in constructing the new\nDharamshalas were considered to be for advancement of the charitable object of the\ntrust which were held to be exempt under section 11 in the case of Satya Vijay Patel\nHindu Dharamshala Trust v. CIT [1972] 86 ITR 683 (Guj.) and this Court in Ragunath\nDas Parihar Dharmshala v. CIT (1986) 158 ITR 432 has held that the sole purpose of\nthe trust was to run a Dharamshala which is an object of general public utility and so\nwhen this was the sole object, the income derived therefrom in the shape of rent of\nDharamshala is exempt under section 11, read with section…

VARDHMAN SATHANAKVASI JAIN SRAVAK SANGH,AJMER vs. CIT(E), JAIPUR, JAIPUR

ITA 696/JPR/2024[NA]Status: DisposedITAT Jaipur27 Sept 2024

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Ajey Malik (CIT)
Section 12ASection 12A(1)(ab)Section 12A(1)(ac)Section 80GSection 80G(5)Section 80G(5)(ii)Section 80G(5)(iii)

…als. The expenses in constructing the new Dharamshala were considered in advancement of the charitable object of the trust which was held entitled to exemption under s. 11 of the said Act in the case of Satya Vijay Patel Hindu Dharamshala Trust vs. CIT (1972) 86 ITR 683 (Guj) and this Court in Raghunath Das Parihar Dharamshala vs. CIT (1986) 158 ITR 432 (Raj) has held that the sole purpose of the trust was to run a dharamshala which is an object of general public utility and so when this was the sole object, the income derived therefrom in shape of rent from the income of dharamshala is exempt under s. 11 r/w s.…

VARDHMAN SATHANAKVASI JAIN SRAVAK SANGH,AJMER vs. CIT(E), JAIPUR, JAIPUR

ITA 695/JPR/2024[NA]Status: DisposedITAT Jaipur27 Sept 2024

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Ajey Malik (CIT)
Section 12ASection 12A(1)(ab)Section 12A(1)(ac)Section 80GSection 80G(5)Section 80G(5)(ii)Section 80G(5)(iii)

…als. The expenses in constructing the new Dharamshala were considered in advancement of the charitable object of the trust which was held entitled to exemption under s. 11 of the said Act in the case of Satya Vijay Patel Hindu Dharamshala Trust vs. CIT (1972) 86 ITR 683 (Guj) and this Court in Raghunath Das Parihar Dharamshala vs. CIT (1986) 158 ITR 432 (Raj) has held that the sole purpose of the trust was to run a dharamshala which is an object of general public utility and so when this was the sole object, the income derived therefrom in shape of rent from the income of dharamshala is exempt under s. 11 r/w s.…

THE BOMBAY SOCIETY OF THE SALESIAN SISTERS INDIA,WADALA MUMBAI vs. INCOME TAX OFFICER - 2 (4), MUMBAI

In the result, the appeal is allowed and the impugned order disallowing the exemption for assessment year 2016-17 is hereby set aside

ITA 2920/MUM/2023[2016-17]Status: DisposedITAT Mumbai12 Dec 2023AY 2016-17

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri Mandar VaidyaFor Respondent: Shri Sunny Kachhwaha Sr.AR
Section 11(1)(a)

…ure of expenditure, being capital expenditure or otherwise is not relevant in the context of section 11(1)(a) of the said Act. Reliance in this regard is placed on the decision of Hon’ble Gujarat High Court in Satya Vijay Patel Hindu Dharmashala Trust vs CIT, 86 ITR 683 (Guj) and the decision of the Hon’ble Supreme Court in S.R.M.CT.M Triuppani Trust vs CIT, 230 ITR 636 (SC) 8. It is submitted that even the owner of the building viz. SSSI, Chennai is also a charitable trust, and was engaged in the similar activity of conducting school. It is submitted that the object of both the trusts being similar, the ITA 292…

THE DY. COMMR. OF INCOME TAX, (EXEMPTION) CIRCLE-2,, AHMEDABAD vs. JAMNAGAR AREA DEVELOPMENT AUTHORITY, JAMNAGAR

In the result, the appeal filed by the Revenue is dismissed

ITA 2425/AHD/2017[2009-10]Status: DisposedITAT Ahmedabad15 Nov 2019AY 2009-10

Bench: Shri Pradip Kumar Kedia & Smt. Madhumita Roy

For Appellant: Shri Alok Singh, CIT.D.R
Section 11Section 11(1)(a)Section 11(2)Section 2(15)

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ ‘B’ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SMT. MADHUMITA ROY, JUDICIAL MEMBER आयकर अपील सं./I.T.A. Nos. 2425 to 2428/Ahd/2017 ("नधा"रण वष" / Assessment Years : 2009-10, 2010-11, 2011-12 & 2014-15) Deputy Commissioner of बनाम/ Jamnagar Area Income-Tax (Exemptions) Development Authority Vs. 1st Floor, Dr. Hedgewar Circle-2, Ahmedabad 2nd Floor, Nature View Commercial Complex, Building, Opp. H. K. Near M. P. Shah College, House, Ashram Road, Sat Rasta, Jamnagar - Ahmedabad - 380009 361001 "थायी…

THE ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. BHOLARAM EDUCATION SOCIETY,, GANDHINAGAR

In the result, the appeal of the revenue is dismissed

ITA 2422/AHD/2017[2014-15]Status: DisposedITAT Ahmedabad15 Nov 2019AY 2014-15
For Appellant: Shri G.C. Pipara, A.RFor Respondent: Shri Kishan Vyas, CIT-D.R
Section 11Section 11(1)(d)Section 13(1)(c)Section 143(2)Section 143(3)Section 4

…on'ble Supreme Court in the case of S.RM.M.CT.M Tiruppani Trust v. CIT [1998] 230 ITR 636 and CIT v. Tiny tots Education Society 330 ITR 21 (P&H) as well as the decision of the Gujarat High Court in the case of Satya Vijay Patel Hindu Dharmashala Trust v. CIT 86 ITR 683 wherein it has been "Held that the amount spent by the trustee in the construction of the new dharamshala was an application of income towards the charitable purposes of the trust". In all the judgments it has been held by the higher authorities that the amount utilized for Requiring Fixed assets is allowable as application of income as per sec. 1…

THE DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. MUDRA FOUNDATION FOR COMMUNICATION RESEARCH & EDUCATION,, AHMEDABAD

In the result, the appeal is dismissed

ITA 2424/AHD/2017[2014-15]Status: DisposedITAT Ahmedabad10 Jun 2019AY 2014-15
Section 11Section 11(1)(a)Section 12ASection 13(8)Section 143(3)Section 2(15)

…333/- squarely falls in the provision of section 11(1)(a) of the Act which provides for deduction against the income. Our view further find support from the judgment of Jurisdictional High Court in the case of Satya Vijay Patel Hindu Dharamshala Trust Vs. CIT 86 ITR 683 wherein Hon’ble Court observed as follows: “As regards the contention whether the whole of the net surplus income of the trust properties applied in constructing the new Dharamshala or only equivalent to 25 per cent of the net income would be exempt from tax, the dominant object of creating the trust being to establish Dharamshala for the benefit…

THE DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. MUDRA FOUNDATION FOR COMMUNICATION RESEARCH & EDUCATION,, AHMEDABAD

In the result, the appeal is dismissed

ITA 2423/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad10 Jun 2019AY 2013-14
Section 11Section 11(1)(a)Section 12ASection 13(8)Section 143(3)Section 2(15)

…333/- squarely falls in the provision of section 11(1)(a) of the Act which provides for deduction against the income. Our view further find support from the judgment of Jurisdictional High Court in the case of Satya Vijay Patel Hindu Dharamshala Trust Vs. CIT 86 ITR 683 wherein Hon’ble Court observed as follows: “As regards the contention whether the whole of the net surplus income of the trust properties applied in constructing the new Dharamshala or only equivalent to 25 per cent of the net income would be exempt from tax, the dominant object of creating the trust being to establish Dharamshala for the benefit…

THE ITO(EXEMPTIONS), WARD-2,, AHMEDABAD vs. POLIO FOUNDATION,, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed

ITA 1958/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad30 Apr 2019AY 2009-10
For Appellant: Shri P.M. Mehta, A.R
Section 11Section 11(2)

…he income would be exempt under section 11. If this was not done, then the income would not be exempt.” 7.4 We also find support and guidance from the judgment of Hon’ble Gujarat HC in the case of Satya Vijay Patel Hindu Dharamshala Trust Vs. CIT reported in 86 ITR 683 wherein it was held as under: “So far as the assessment years 1962-63 and 1963-64, governed by section 11 of the 1961 Act were concerned, the question to be decided was whether the use of trust money in construction of new dharamshala was investment of trust fund in furtherance of the trust objectives. The only requirement of section 11(1)(a) is…

THE ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. BHOLARAM EDUCATION SOCIETY,, GANDHINAGAR

In the result, the appeal of the revenue is dismissed

ITA 3041/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad29 Mar 2019AY 2012-13
For Appellant: Shri Ramesh Chandra Pandey, CIT-DRFor Respondent: Shri Alog Saiyed, AR
Section 11Section 12ASection 13(1)(c)

…on'ble Supreme Court in the case of S.RM.M.CT.M Tiruppani Trust v. CIT [1998] 230 ITR 636 and CIT v. Tiny tots Education Society 330 ITR 21 (P&H) as well as the decision of the Gujarat High Court in the case of Satya Vijay Patel Hindu Dharmashala Trust v. CIT 86 ITR 683 wherein it has been "Held that the amount spent by the trustee in the construction of the new dharamshala was an application of income towards the charitable purposes of the trust". In all the judgments it has been held by the higher authorities that the amount utilized for Requiring Fixed assets is allowable as application of income as per sec. 1…

THE DY.DIT, (EXEMP.),, AHMEDABAD vs. MUDRA FOUNDATION FOR COMMUNICATIONS, RESEARCH & EDUCATION,, AHMEDABAD

In the result, both the appeals of the Revenue and both the cross objections filed by the assessee are dismissed

ITA 2872/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad12 Oct 2017AY 2010-11
For Appellant: Shri Sanjay R. Shah, A.RFor Respondent: Shri Prasoon Kabra, Sr. D.R
Section 11Section 11(1)(a)Section 11(2)Section 13(8)Section 143(2)Section 2(15)

…333/- squarely falls in the provision of section 11(1)(a) of the Act which provides for deduction against the income. Our view further find support from the judgment of Jurisdictional High Court in the case of Satya Vijay Patel Hindu Dharamshala Trust Vs. CIT 86 ITR 683 wherein Hon’ble Court observed as follows: I.T.A Nos.2872 & 3090 & CO Nos.317-318/Ahd/2014 A.Y.2010-11 & 2011-12 Page No 10 DCIT vs. Mudra Foundation for Communications Research & Education As regards the contention whether the whole of the net surplus income of the trust properties applied in constructing the new Dharamshala or only equivalent…

SHREE JAIN SAMITI,JAIPUR vs. CIT(EXEMPTIONS), JAIPUR

In the result, appeal of the assesse is allowed for statistical purposes

ITA 904/JPR/2016[]Status: DisposedITAT Jaipur10 Feb 2017

Bench: Us. The Ld Ar Of The Assessee Has Reiterated The Submission As Made In The Written Submissions & Vehemently

For Appellant: Shri H.P. Gurjar (CIT)For Respondent: Shri P.C. Parwal (CA) fu/kZkfjrh dh vksj ls@
Section 12ASection 2Section 2(15)

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR Jh dqy Hkkjr] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 904/JP/2016 Application Under Section : 12AA cuke Shree Jain Samiti, CIT (Exemptions) Vs. Plot No. 2, Behind Maheshwari Jaipur. Bhawan, Jhalawar Road, Kota LFkk;h ys[kk la-@thvkbZvkj la-@PAN /GIR No.: AALTS 3417 L vihykFkhZ@Appellant izR;FkhZ@Respondent jktLo dh vksj ls@ Revenue by : Shri P.C. Parwal (CA) fu/kZkfjrh dh vksj ls@ Assessee by : Shri H.P. Gurjar (CIT)…

Satya Vijay Patel Hindu Dharamshala Trust v. CIT (86 ITR 683) — Cited in 12 Judgments | BharatTax