Sonepat Hindu Educational and Charitable Society v. CIT

278 ITR 262High Court2005#4556 most cited

What is Sonepat Hindu Educational and Charitable Society v. CIT authority for?

Registration of an institution under Section 12A of the Income Tax Act is sufficient proof that it was established for charitable purposes, and therefore, registration under Section 80G cannot be denied solely on the basis that the institution is not for charitable purposes.

26

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2024.

Also referred to as

Sonepat Hindu Educational and Charitable Society v. CIT · Section 12A · Section 80G · charitable purposes · registration sufficient proof · denial of 80G

Sections most often in play

Section 12ASection 12AASection 80G(5)(iii)

Issues it is cited on

section 12aasection 12asection 12

Judgments citing Sonepat Hindu Educational and Charitable Society v. CIT

ZINDAGI SOCIETY,NEW DELHI vs. CIT(E), NEW DELHI

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 3716/DEL/2024[2023-24]Status: DisposedITAT Delhi19 Dec 2024AY 2023-24

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarzindagi Society Vs. Cit(E) 158, Ground Floor, Civic Centre, Sandesh Vihar, Pitampura Minto Road, New Delhi – 110 034 New Delhi – 110 002 Pan : Aaaaz 1691 B (Appellant) (Respondent) Assessee By Shri R. S. Singhavi, C.A. & Shri Satyajit Goyal, C.A. Respondent By Ms. Harpreet Kaur Hansra, Sr. D.R. Date Of Hearing 19.12.2024 Date Of Pronouncement 19.12.2024 O R D E R Per Vimal Kumar, Jm:

Section 12ASection 80GSection 80G(5)(iii)

…s. CIT(E) ITA No.6487/Del/2018 order dated 06.02.2019 which was allowed in favour of the applicant by following the decision of Hon’ble Jurisdictional Punjab and Haryana High Court in the case of Sonepat Hindu Educational and Charitable Society vs. CIT (2005) 278 ITR 262 (P&H) in which it was held that registration of an institution under section 12A of the Act is sufficient to of its being established for charitable purposes. Thus, registration under section 80G of the Act cannot be denied. 5. Learned Departmental Representative for the Department of Revenue submitted that applicant had failed to file relevant…

VISION DIVYANG FOUNDATION,NEW DELHI vs. CIT(E), NEW DELHI

The appeal is allowed and the impugned order of Ld

ITA 6931/DEL/2019[2019-20]Status: DisposedITAT Delhi20 Feb 2023AY 2019-20

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmavision Divyang Foundation Vs. Commissioner Of Income Tax Plot No. 4, Pocket-A-1, (Exemption), Delhi Sector-8, Rohini, New Delhi Pan : Aactv6355P (Appellant) (Respondent)

Section 12Section 12ASection 80GSection 80G(5)

…h in Bharat Vikas Parishad Maharana vs Cit (Exemption) Hqtr. Vide, ITA.No.6487/Del./2018 where in after taking into consideration Hon'ble Punjab and Haryana High Court Judgement of in the case of Sonepat Hindu Educational and Charitable Society vs. CIT (2005) 278 ITR 262 (P & H), Hon'ble Delhi High Court judgement in the case of DIT vs. Foundation of Ophthalmic & Optometry Research Education Centre 2012 (8) TMI 77 (Del.), the Delhi Bench held; “5. After considering the rival submissions, we are of the view that Order under section 80G(5) denying approval to the assessee cannot be sustained in Law. It is not in d…

CAREER EDUCOM ACADEMY,RAIPUR vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BHOPAL

In the result, the appeal of assessee is allowed

ITA 204/RPR/2018[section 80G]Status: DisposedITAT Raipur21 Sept 2022

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.204/Rpr/2018 (ननधाारण वषा / Assessment Year :Na) Career Educom Academy, Vs Cit(Exemption), Bhopal Jalvihar Colony, Raipur-492001 Pan No. : Aaecc 3374 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 12ASection 13(1)(c)Section 80GSection 80G(5)Section 80G(5)(vi)

…which and a positive satisfaction qua which, is a pre-condition for an approval under section 80G. It may here be pertinent to draw attention to the observations of the jurisdictional High Court in CIT v. Sonepat Hindu Educational & Charitable Society [2005] 278 ITR 262/147 Taxman 1 (Punj. & Har.), requiring the competent authority to enquire into the „real purpose‟ of the applicant, i.e., distinct and apart from that stated in the memorandum of objects, as well as that in CIT v. Sant Girdhar Paramhans Sant Ashram [IT Appeal No. 50 of 2018, dated 16-5- 2018], also read out during hearing, that a mere possibility…

ACIT, NEW DELHI vs. M/S. MAHARAJI EDUCATION TRUST, GHAZIABAD

The appeal are dismissed

ITA 5138/DEL/2016[2007-08]Status: DisposedITAT Delhi13 Oct 2021AY 2007-08

Bench: Shri Kuldip Singh & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Suresh Gupta, C. AFor Respondent: Ms. Paramita M. Biswas[CIT]–
Section 11Section 12ASection 132Section 133ASection 143(1)Section 143(2)Section 143(3)Section 68Section 69Section 69C

…tion as to whether the trust is charitable or not, as held by the Hon'ble Supreme Court in the case of Surat City Gymkhana 300 ITR 214 (SC). The Hon'ble Punjab & Haryana High Court in the case of Sonepat Hindu Educational and Charitable Society Vs. CIT (2005) 278 ITR 262 have held that "Registration of an Institution u/s 12A is sufficient proof of it being established for charitable purpose." Similar view has been affirmed in the decisions of CIT Vs. Ootacamund Gymkhana Club 110 ITR 392 (Mad.), Madhya Pradesh Madhyan Vs. CIT 256 ITR 277 (MP) and Hiralal Bhagwati Vs. CIT ) 246 ITR 188, 193 (Guj.) approved by Apex…

PRADEEP EDUCATION SOCIETY,HARYANA vs. CIT (EXEMPTIONS), CHANDIGARH

The appeal of the assessee stands allowed

ITA 2334/DEL/2017[]Status: DisposedITAT Delhi09 Jun 2020

Bench: Shri G.S. Pannu, Hon’Ble & Shri Sudhanshu Srivastavaasstt. Year -

For Appellant: Shri R.P. Basra, CAFor Respondent: Smt. Sushma Singh, CIT(DR)
Section 12ASection 80GSection 80G(5)

…und for rejecting assessee’s application u/s 80G. 6.1 The Hon’ble High Court of Punjab & Haryana, which is the Jurisdictional High Court for the assessee society, in the case of Sonipat Hindu Educational & Charitable Society vs. CIT & Anr. reported in (2005) 278 ITR 262, while deciding assessee’s appeal against rejection of assessee’s application for recognition u/s 80G (5) of the Act, held that while dealing with the application u/s 80G (5), the scope of inquiry by the CIT (E) extends to eligibility to exemption under various provisions referred to in that sub- section but not to actual computation of income un…

KHAGOL MANDAL,MUMBAI vs. D.I.T. (EXEMPTION), MUMBAI

In the result, appeal of the assessee is allowed, as above

ITA 4538/MUM/2012[2008-09]Status: DisposedITAT Mumbai07 Jun 2019AY 2008-09

Bench: Shri G.S. Pannu & Shri Amarjit Singhassessment Year : 2008-09

For Appellant: Shri. Nishant ThakkarFor Respondent: Shri. R.P.Meena & Harkamal Sohi
Section 12ASection 80GSection 80G(5)

…re is no adverse view taken so as to jeopardise assessee’s claim for exemption under Sections 11/12 of the Act. On the point of law, the Learned Representative relied upon the following judgments :- (i) Sonepat Hindu Educational & Charitable Society vs. CIT, 278 ITR 262 (P&H); (ii) CIT vs. Sewa Bharti Haryana Pradesh, 325 ITR 599 (P&H); and, (iii) Shri Chandrabhan Athare Patil Gram Navodaya Trust vs CIT-1, Pune, [2012] 22 taxmann.com 406 (Pune) 7. Insofar as the factual aspects are concerned, the Learned Representative referred to the Annual Accounts of the preceding three years to point out that substantial fu…

BHARAT BHUSHAN JAIN CHARITABLE TRUST,NEW DELHI vs. CIT(E), NEW DELHI

In the result, appeal of Assessee is allowed

ITA 750/DEL/2018[-]Status: DisposedITAT Delhi12 Feb 2019

Bench: Shri Bhavnesh Saini, J.M. & Shri L.P. Sahu, A.M.

For Appellant: Shri D.B. Jain, C.AFor Respondent: Shri Sanjay Goyal, CIT-D.R
Section 12ASection 80GSection 80G(5)Section 80G(5)(vi)

…ate orders regarding approval granted u/s 80G(5)(vi) in accordance with law.” 3.1. He has also relied upon similar decision of Hon’ble jurisdictional Punjab and Haryana High Court in the case of Sonepat Hindu Educational and Charitable Society vs. CIT (2005) 278 ITR 262 (P & H) in which it was held that registration of an institution under section 12A of the Act is sufficient to of its being established for charitable purposes. Thus, registration under section 80G cannot be denied. He has also relied upon decision of the Hon’ble Delhi High Court in the case of DIT vs. Foundation of Ophthalmic & Optometry Researc…

BHARAT VIKAS PARISHAD MAHARANA PRATAP NYAS,GURGAON vs. CIT(EXEMPTION) HQTR., CHANDIGARH

In the result, appeal of Assessee is allowed

ITA 6487/DEL/2018[-]Status: DisposedITAT Delhi06 Feb 2019

Bench: Shri Bhavnesh Saini, J.M. & Shri L.P. Sahu, A.M.

For Appellant: Miss. Umang LuthraFor Respondent: Shri Sanjay Goyal, CIT-D.R
Section 12ASection 80GSection 80G(5)(vi)

…4 ITA.No.6487/Del./2018 Bharat Vikas Parishad Maharana Pratap Nyas, Gurgaon. 3.1. He has also relied upon similar decision of Hon’ble jurisdictional Punjab and Haryana High Court in the case of Sonepat Hindu Educational and Charitable Society vs. CIT (2005) 278 ITR 262 (P & H) in which it was held that registration of an institution under section 12A of the Act is sufficient to of its being established for charitable purposes. Thus, registration under section 80G cannot be denied. He has also relied upon decision of the Hon’ble Delhi High Court in the case of DIT vs. Foundation of Ophthalmic & Optometry Researc…

M/S MADAD CHARITABLE FOUNDATION,AMRITSAR vs. COMM OF INCOME TAX ( EXAMPTION), CHANDIGARH

In the result, the assessee’s appeal is allowed

ITA 225/ASR/2017[0]Status: DisposedITAT Amritsar01 Jan 2019

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 225/(Asr)/2017 Assessment Year:

For Appellant: Sh. Satish Bansal (C.A.)For Respondent: Smt. Parwinder Kaur, CIT-DR
Section 12ASection 80Section 80G(5)(vi)

…e trust, i.e., as set out in the Memorandum of Association or the trust deed. The purpose being to find the real purpose of the establishment of the trust, as against its’ ostensible purpose (refer: Sonepat Hindu Educational & Charitable Society v. CIT [2005] 278 ITR 262 (P&H), relied upon by the assessee). That said, we find no reason not to accept the assessee’s case. There is nothing in the trust deed, or the appellant’s activities, detailed in the ‘Notes on its activities’ forming part of its’ application in Form 10G (at PB page 44), as well as in reply (dated 25/2/2017) to the show cause letter (at PB page 4…

M/S CHANDIGARH LAWN TENNIS ASSOCIATION,CHANDIGARH vs. ITO (EXEMPTIONS), CHANDIGARH

ITA 1382/CHANDI/2016[2013-14]Status: DisposedITAT Chandigarh26 Jul 2018AY 2013-14

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year : 2013-14 Chandigarh Lawn Tennis Vs. The Ito (Exemptions), Association, Ward, Chandigarh Sector 10, Chandigarh Pan No. Aaatc4943J (Appellant) (Respondent) Appellant By : Sh. Y.K. Sud, Ca Respondent By : Smt. Chanderkanta, Addl. Cit (On 22.3.2018) & Sh.Yoginder Mittal, Sr. Dr (On 13.7.2018) Date Of Hearing : 22.03.2018 & 13.7.2018 Date Of Pronouncement : 26.07.2018

For Appellant: Sh. Y.K. Sud, CAFor Respondent: Smt. Chanderkanta, Addl. CIT (on 22.3.2018)
Section 11Section 12ASection 13(8)Section 2(15)

…IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘A’ CHANDIGARH BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND Ms. ANNAPURNA GUPTA, ACCOUNTANT MEMBER Assessment Year : 2013-14 Chandigarh Lawn Tennis Vs. The ITO (Exemptions), Association, Ward, Chandigarh Sector 10, Chandigarh PAN No. AAATC4943J (Appellant) (Respondent) Appellant by : Sh. Y.K. Sud, CA Respondent by : Smt. Chanderkanta, Addl. CIT (on 22.3.2018) & Sh.Yoginder Mittal, Sr. DR (on 13.7.2018) Date of Hearing : 22.03.2018 & 13.7.2018 Date of Pronouncement : 26.07.2018 ORDER Per Sanjay Garg, Judicial Member: The present appeal has been preferred b…

ACIT, NEW DELHI vs. DLF QUTAB ENCLAVE COMPLEX EDUCATIONAL CHARITABLE TRUST, NEW DELHI

ITA 5253/DEL/2016[2012-13]Status: DisposedITAT Delhi29 Jun 2018AY 2012-13

Bench: Shri Amit Shukla & Shri O.P. Kant

For Appellant: Shri R. S. Singhvi, CA &For Respondent: Shri Vijay Kumar Jiwani, Sr. DR
Section 11Section 11(1)Section 12ASection 12BSection 143(3)

…- INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER ITA No.:-5253/Del/2016 Assessment Year: 2012-13 ACIT(E), Circle 1(1), E-2 Block, DLF Qutab Enclave Pratyaksh Kar Bhawan, Complex Educational Vs. Dr. Shyama Prasad Mukherjee Charitable Trust, Civic Centre, 9th Floor, DLF Centre, New Delhi. Sansad Marg, New Delhi – 110 001 (Appellant) (Respondent) Department by: Shri Vijay Kumar Jiwani, Sr. DR Assessee by : Shri R. S. Singhvi, CA & Shri Satyajeet Goel Date of Hearing 30/05/2018 Date of 29/06/2018 pronouncement O R D E R PE…

M/S. PARBHAT HEAVY FORGE PVT. LTD.,PUNJAB vs. ADDL. CIT, KARNAL

In the result, appeal of the assessee is allowed partly for statistical purposes

ITA 5288/DEL/2016[2011-12]Status: DisposedITAT Delhi20 Jun 2018AY 2011-12

Bench: Sh. Amit Shukla & Sh.O.P. Kantassessment Year: 2011-12 Prabhat Heavy Forge Pvt. Vs. Addl.Cit, Ltd., Karnal Range, Karnal V. Gupta & Associates, Cas, D-15, Calibre Market, Rajpur Punjab Pan :Aaccp6521A (Appellant) (Respondent) Appellant By Sh. Sandeep Sapra, Adv. Respondent By Sh. Atiq Ahmed, Sr.Dr

Section 143(2)Section 143(3)Section 36Section 36(1)(iii)Section 40A(2)(b)

…. In support of the rule of consistency, the Ld. counsel relied on following judicial precedents: " 385 ITR 295, CIT Vs. Excel Industries Ltd. (Supreme court) 11 " 193 ITR 321-323 Radhasoami Satsang Vs. CIT (Supreme Court) also followed by P&H High Court in 278 ITR 262. " 264 ITR 276, CIT Vs. ARG Securities Printers (Jurisdictional Delhi High Court). " 300 ITR 75 (Delhi), Director of Income Tax (E) Escorts Cardiac Diseases. 5.3 On the contrary, the Ld. DR submitted that interest paid to the persons specified under section 40A(2)(b) is being excessive as compared to the interest paid on money borrowed by the as…

SANJIVANI FOUNDATION,,AHMEDNAGAR vs. COMMISSIONER OF INCOME-TAX:1,,

In the result, the appeal of the assessee is allowed

ITA 2129/PUN/2014[]Status: DisposedITAT Pune10 Jan 2018

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

For Appellant: Shri Abhay A. ShastriFor Respondent: Shri Rajeev Kumar, CIT
Section 12ASection 80GSection 80G(5)Section 80G(5)(vi)

…Act and the approval has not been withdrawn. The aforesaid submission of the assessee has not been controverted by the Revenue. We find that Hon’ble Punjab and Haryana High Court in the case of Sonepat Hindu Educational and Charitable Society Vs. CIT (2005) 278 ITR 262 (P&H) has held that Registration of an Institution u/s 12A of the Act is sufficient proof of it being established for charitable purposes. It further held that in continuing the purpose of the Trust for the purposes of approval u/s 80G of the Act, it is important to find out the real purpose of establishing the Trust rather than just relying on…

REGIONAL EDUCATION DEVELOPMENT WELFARE SOCIETY,GURGAON vs. CIT, FARIDABAD

The appeal of the assessee is allowed

ITA 6513/DEL/2014[]Status: DisposedITAT Delhi04 Oct 2017

Bench: Shri G.D. Agrawal, Hon’Ble & Shri Sudhanshu Srivastava

For Appellant: Shri Kapil Goel, AdvFor Respondent: Shri Atiq Ahmad, Sr. DR
Section 12ASection 143(3)Section 2(15)

…f the society etc and the genuineness of its objects which in present case is admittedly fulfilled. 4.2 The Ld. AR placed reliance on the judgment of the Jurisdictional Punjab & Haryana High Court in the case of Sonepat Hindu Educational Society reported in 278 ITR 262 (P&H). The Ld. AR also relied on the following judicial precedents- i. Hon’ble Punjab & Haryana High Court decision in case of IILM Foundation Academy, order dated 26.09.2016 (ITA no. 198/2011) ii. Hon’ble Kerala High Court decision in case of Sree Anjaneya Medical Trust reported in 382 ITR 399 iii. Hon’ble Supreme Court’s decision in the cas…

SHREE NITAI GAURA HARI SANKIRTAN MANDAL TRUST,GHAZIABAD vs. CIT (E), LUCKNOW

Appeal is allowed

ITA 5325/DEL/2016[]Status: DisposedITAT Delhi30 Aug 2017

Bench: Shri I. C. Sudhir & Shri O. P. Kant

For Appellant: Shri P. C. Yadav, AdvFor Respondent: Shri S. S. Rana, CIT [DR]
Section 12ASection 80G

…1 I.T. Appeal No. 5325/Del/2016 Assessment Year : – – – IN THE INCOME TAX APPELLATE TRIBUNAL [ DELHI BENCHES : “G” NEW DELHI ] BEFORE SHRI I. C. SUDHIR, JUDICIAL MEMBER AND SHRI O. P. KANT, ACCOUNTANT MEMBER I.T. Appeal No. 5325/Del/2016 Assessment Year : – – – Shree Nitai Gaura Hari Commissioner of Income Tax, Sankirtan Mandal Trust, Vs. [ Exemption ]; C/o. L.M. Agarwal & Co., C.As.; Lucknow. KA–32, Kavi Nagar, Ghaziabad – 201 001. PAN : AAKTS 5376 D (Appellant) (Respondent) Assessee by : Shri P. C. Yadav, Adv.; Department by : Shri S. S. Rana, CIT [DR]; Date of Hearing : 08.08.2017 Date of Pronoun…

ADIT (E), DELHI vs. M/S ASIAN CENTRE FOR ORGANISATION RESEARCH & DEVELOPMENT., NEW DELHI

In the result, all these appeals filed by the Revenue are dismissed

ITA 3718/DEL/2012[2003-04]Status: DisposedITAT Delhi16 Jun 2017AY 2003-04

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

Section 10Section 12ASection 143(1)Section 143(3)Section 148Section 80G

…mains unchallenged. For this reason alone, by virtue of the provisions of Section 80G (5) (vii), the application filed by the assessee is entitled to be allowed and we hold so. 13. Further, in 'Sonepat Hindu Educational and Charitable Society vs. CIT and Anr, 278 ITR 262 (P&H), relied on by the Id. counsel for the assessee, it has been held, Inter alia, that the scope of inquiry by the Commissioner, while dealing with the application u/s 80G (5) of the Act extends to eligibility to exemption under various provisions of the Act referred to in the Section, but not actual computation of income under the Act, particu…

DCIT, MEERUT vs. M/S. JANKI NEWSPRINT LTD., MEERUT

In the result, the both the appeals of assessee and Revenue are partly allowed for statistical purposes

ITA 4938/DEL/2015[2011-12]Status: DisposedITAT Delhi12 May 2017AY 2011-12

Bench: : Shri S.K. Yadav & Shri L.P. Sahu

For Respondent: 1.Whether in the facts and circumstances of the case, the Ld

…has been allowed by the Dept. itself in the subsequent years, therefore, Rules of consistency also apply for which reliance is placed on the following case laws: 193 ITR 321-323 Radhasoami Satsang Vs. CIT, (Supreme Court) also followed by P & H High Court in 278 ITR 262: "We are aware of the fact that, strictly speaking, resjudicata does not apply to income-tax proceedings Again, each assessment year being a unit, what is decided in one year may not apply in the following year but where a fundamental aspect permeating through the different assessment years has been found as a fact one way or the other and partie…

PATANJALI YOGPEETH (NYAS),DELHI vs. ADIT(EXEMPTION), NEW DELHI

Appeal is allowed

ITA 2267/DEL/2013[2009-10]Status: DisposedITAT Delhi09 Feb 2017AY 2009-10

Bench: Shri I.C. Sudhir & Shri L. P. Sahu

For Appellant: Shri Ajay Vohra, Sr. Adv.; &For Respondent: Shri N. C. Swain, CIT [DR]
Section 11(1)(a)Section 11(5)Section 13Section 142Section 2(15)

…he assessee are not charitable in nature. Reference, in this regard may be made to the following decisions: ACIT V. Surat City Gymkhana: 300 ITR 214 (SC) (Refer page 1066-1067 of case law  paperbook) Sonepat Hindu Educational and Charitable Society v. CIT.: 278 ITR 262 (P&H) (Refer  page 1068-1072 of caselaw paperbook)  Hiralal Bhagwati vs CIT: 246 ITR 188(Guj.)  Ananda Marga Pracharaka Sangha v. CIT: 218 ITR 254 (Cal) ITO v. Mrs. Dwarika Prasad Trust: 30 ITD 84 (Third Member)(Del.)  ITO v. Trilok Tirath Vidyavati Chuttani Charitable Trust: 90 ITD 569 (Chd)   Gaur Brahmin Vidya Pracharini Sabha v. CIT: 34…

CREDIT GURANTEE FUND TRUST,MUMBAI vs. ITO (E) 1(1), MUMBAI

In the result, the appeal of the assessee is allowed, as above

ITA 6282/MUM/2014[2010-11]Status: DisposedITAT Mumbai20 Jan 2017AY 2010-11

Bench: Shri G.S.Pannu & Shri Amit Shuklacredit Guarantee Fund Trust For Micro & Small Enterprises, 7Th Floor, Sme Development Centre, G-Block, Bandra Kurla Complex, Bandra(E), Mumbai 400 051 Pan:Aaatc 2613D ...... Appellant Vs. The Income Tax Officer (Exemptions), Pirmal Chambers, Parel, Mumbai 400 012 .... Respondent

For Appellant: Shri Arvind SondeFor Respondent: Shri Prawin Kumar
Section 11Section 11(2)Section 11(3)Section 143(3)Section 263

…meaning of the expression ‘charitable purpose’ contained in section 2(15) of the Act. In support, reliance has been placed on the following judgments: (i) Hira Lal Bhagwati V CIT 246 ITR 188(Guj) (ii) Sonepat Hindu Educational and Charitable Society vs. CIT, 278 ITR 262(P&H) (iii) Madhya Pradesh Madhyam vs. CIT, 256 ITR 277(M.P) 11 5.2 On this aspect of the matter, the Ld. CIT-DR has merely reiterated the stand of the CIT(A), while not joining issues so far as the ratio laid down in the above judgments relied upon by the appellant assessee is concerned. 5.3 At the time of hearing, it was specifically put to t…

JCIT, GHAZIABAD vs. M/S. SYSTEM CONTROLS & TRANSFORMERS PVT. LTD., GHAZIABAD

In the result, the appeal filed by revenue is allowed and the appeal filed by assessee is

ITA 5335/DEL/2011[1994-95]Status: DisposedITAT Delhi13 Jan 2017AY 1994-95

Bench: Smt Diva Singh & Shri Anadi N. Mishrasystem Controls & Transformers Pvt. Jcit, Ltd., Range-2, Cgo-2, Vs. Ghaziabad Urban Cooperative Bank Ltd, Hapur Road, Ghaziabad Ghaziabad (Appellant) (Respondent)

For Appellant: S/sh. Sanjiv Sapra, Adv & A.S. Jindal
Section 145(2)Section 234BSection 40A(3)

…Further he had also not appreciated the fact that such interest was an accrued liability and was not a contingent liability. Rule of consistency is also invoked as held in 193 ITR 321-323 Radhasoami Satsang Vs. CIT (SC) also followed by P & FI Fligh Court in 278 ITR 262 and 264 ITR 276, CIT Vs. ARG Securities Printers (Delhi Ftigh Court) (iii) Reduction In outstanding loan amount balance as per Balance Sheet as on 31- 03-1994 and 31-03-1993 as per annual account statements-Schedule 3 at Page 34 of first paper book indicates payment towards interest during the year. Ground No. 5(B) Additional Depreciation Rs.3…

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