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“Section 52(2)”

Section References (mined)Section 52Section 52(2)73 judgments

SIDDHI VINAYAK SHIKSHA PRASAR EVAM SAMAJ KALYAN SAMITI,GWALIOR vs. CIT(EXEMPTION), BHOPAL

In the result, the both the appeals ITA No

ITA 579/AGR/2025[2025-26]Status: DisposedITAT Agra20 Feb 2026AY 2025-26

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 12A(1)(ac)Section 80G(5)(iv)

IN THE INCOME TAX APPELLATE TRIBUNAL, AGRA BENCH, AGRA BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR

SIDDHI VINAYAK SHIKSHA PRASAR EVAM SAMAJ KALYAN SAMITI ,GWALIOR vs. CIT(EXTEMPTION) , BHOPAL

In the result, the both the appeals ITA No

ITA 578/AGR/2025[2025-26]Status: DisposedITAT Agra20 Feb 2026AY 2025-26

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 12A(1)(ac)Section 80G(5)(iv)

IN THE INCOME TAX APPELLATE TRIBUNAL, AGRA BENCH, AGRA BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR

SHRI ACHLESHWAR MAHADEVJI JI SARVJANIK NIYAS,GWALIOR vs. CIT(E), BHOPAL

In the result, the appeal is allowed for statistical purposes

ITA 417/AGR/2025[2025-26]Status: DisposedITAT Agra16 Feb 2026AY 2025-26

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year : 2025-26 Shri Achleshwar Mahadev Ji V Cit (Exemption) Sarvajanik Nyas, Sanatan Bhopal Dharm Mandir Road Gwalior- 474 001 Pan : Aahts1225J (Appellant) (Respondent)

Section 80GSection 80G(5)(iii)

IN THE INCOME TAX APPELLATE TRIBUNAL, AGRA BENCH, AGRA BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR

ARTH FOUNDATION,NASHIK vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE, PUNE

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 2258/PUN/2025[2026-27]Status: DisposedITAT Pune29 Jan 2026AY 2026-27

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2258/Pun/2025 निर्धारण वषा / Assessment Year: 2026-27 Arth Foundation, V Commissioner Of Income Flat No.3, Tulip Apartment, S Tax (Exemption), Pune. Suyojit Garden, Gangapur Road, Nashik – 422013. Pan: Aahta2324C Appellant/ Assessee Respondent / Revenue Assessee By Ca Trishala R Jain (Virtual) Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 21/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Passed Under Section 80G Of The Income Tax Act, 1961 Dated 01.08.2025. The Assessee Has Raised The Following Grounds Of Appeal : ―1. The Learned Cit(E), Pune Has Erred In Rejecting The 1 Application Of The Appellant Trust Filed U/S 80G(5)(Iii) Of The Act Without Considering The Merits Of The Case.

Section 80GSection 80G(5)Section 80G(5)(iii)Section 80G(5)(iv)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

MANJREKAR FOUNDATION,PUNE vs. CIT, EXEMPTION, PUNE, PUNE

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 2338/PUN/2025[-]Status: DisposedITAT Pune27 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2338/Pun/2025 निर्धारण वषा / Assessment Year: - Manjrekar Foundation, V Cit Exemption, Near Goodluckchowk, Decan S Pune. Gymkhana, Bhandarkar Road, Deccan Gymkhana, Pune – 411004. Pan: Aactm7144D Appellant/ Assessee Respondent / Revenue Assessee By Smt Deepa Khare Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 22/01/2026 Date Of Pronouncement 27/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Passed Under Section 80G Of The Income Tax Act, 1961 Dated 30.08.2025. The Assessee Has Raised The Following Grounds Of Appeal : ―1. The Ld. Cit Exemption Erred In Law & On Facts In Treating The Application Under Clause (Iii) Of First Proviso To Sub-Section (5) Of Section 80G As Non- Maintainable On The Ground Of Being Filed Beyond The Statutory Period As Provided In Clause (Iii) Of First Proviso To Section 80G (5) & Thereby Rejecting The Same Without Going Into The Merits.

Section 10Section 11Section 3Section 80GSection 80G(5)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

SHREE CHAITANYA-RAM FOUNDATION,BAVDHAN PUNE vs. CIT EXEMPTION, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 2619/PUN/2025[2025-2026]Status: DisposedITAT Pune21 Jan 2026AY 2025-2026

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Prashant Gadekar, CIT
Section 12(1)(ac)Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

SHREE CHAITANYA-RAM FOUNDATION,BAVDHAN vs. CIT EXEMPTION, PUNE

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 2618/PUN/2025[2025-2026]Status: DisposedITAT Pune21 Jan 2026AY 2025-2026

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Prashant Gadekar, CIT
Section 12(1)(ac)Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

MOHANJI BHARAT WELFARE FOUNDATION,MUMBAI vs. CIT (EXEMPTION), MUMBAI

In the result, the appeal filed by the assessee is allowed for\nstatistical purposes in above terms

ITA 2617/MUM/2025[-]Status: DisposedITAT Mumbai14 Oct 2025
Section 11(1)(c)Section 80G

absurd and unreasonable to apply\nSection 52(2) according to its strict literal construction. We must,\ntherefore, eschew literalness in the interpretation of section 52(2) and try\nto arrive at an interpretation which avoids this absurdity and mischief\nand makes the provision rational and sensible, unless of course

NATIONAL ASSOCIATION FOR THE BLIND,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed for statistical purpose

ITA 2490/MUM/2025[2026-27]Status: DisposedITAT Mumbai29 Aug 2025AY 2026-27

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2026-27

For Appellant: Ms. Jasmin Amalsadvala, Ld. A.RFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. D.R
Section 11Section 80GSection 80G(5)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

JYPORE MANUFACTURING JEWELLERS PRIVATE LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 432/JPR/2025[2018-19]Status: DisposedITAT Jaipur25 Jun 2025AY 2018-19
For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 127Section 133ASection 142(1)Section 143(2)

Varghese v. ITO [1981] 131 ITR\n597/7 Taxman 13 (SC). In the above referred cases mainly the question was\ninvolved under section 52(2) for reopening the case under section 147A/147B of\nthe Act and the decision in the case of K.P. Varghese (supra)is a leading case.\nThe principles

SUNWORLD SOCIETY FOR SOCIAL SERVICE,PUNE vs. CIT EXEMPTION, PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 796/PUN/2025[-]Status: DisposedITAT Pune26 May 2025

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri B. Y. Chavan
Section 12ASection 12A(1)(ac)Section 80Section 80G

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

SUNWORLD SOCIETY FOR SOCIAL SERVICE,PUNE vs. CIT EXEMPTION, PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

ITA 795/PUN/2025[-]Status: DisposedITAT Pune26 May 2025

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Smt. Deepa KhareFor Respondent: Shri B. Y. Chavan
Section 12ASection 12A(1)(ac)Section 80Section 80G

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

YOG VIDYA GURUKUL,PUNE vs. CIT EXEMPTION, PUNE, PUNE

In the result, appeal of the assessee is allowed for statistical purpose

ITA 797/PUN/2025[-]Status: DisposedITAT Pune23 May 2025

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.797/Pun/2025 Yog Vidya Gurukul, Vs. Cit, Exemption, Pune. 3 Ksitij Sanjwat Hsg. Society, Near Suvarnayog Sah. Bank Bibwewadi, Pune- 411037. Pan : Aaaty3279P Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri B. Y. Chavan Date Of Hearing : 14.05.2025 Date Of Pronouncement : 23.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.02.2025 Passed By Ld. Cit, Exemption, Pune Rejecting The Application For Registration U/S 80G Of The It Act. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Ld Cit Exemption Erred In Law & On Facts In Treating The Application Under Clause (Iii) Of First Proviso To Sub-Section (5)

For Appellant: Smt. Deepa KhareFor Respondent: Shri B. Y. Chavan
Section 80GSection 80G(5)Section 80G(5)(iv)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

MITCON FORUM FOR SOCIAL DEVELOPMENT,PUNE vs. CIT EXEMPTION, PUNE

In the result, appeal of the assessee is allowed for statistical purpose

ITA 613/PUN/2025[2024-25]Status: DisposedITAT Pune24 Apr 2025AY 2024-25

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.613/Pun/2025 िनधा"रण वष" / Assessment Year: 2024-25 Mitcon Forum For Social V The Commissioner Of Development, S Income Tax(Exemption), Kebera Chambers, 1St Floor, Pune. Shivajinagar, Pune – 411005. Maharashtra Pan: Aalcm9558M Appellant/ Assessee Respondent / Revenue Assessee By Shri Sharad A Vaze – Ar Revenue By Shri Ramnath P Murkude – Cit-Dr Date Of Hearing 22/04/2025 Date Of Pronouncement 24/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax-Exemption, Pune Passed Under Section 80G(5) Of The Income Tax Act, 1961; Dated 19.02.2025. 2. The Assessee Has Raised The Following Ground Of Appeal : “1. On The Basis Of Facts & In The Circumstances Of The Case & As Per Law, The Commissioner Of Income Tax,(Exemptions) Pune, Is Not

Section 10Section 11Section 12ASection 13(1)Section 80GSection 80G(5)Section 80G(5)(iii)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

SHRI SHARDAGRAM ALUMNI EDUCATION AND CHARITABLE TRUST,RAJKOT vs. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is allowed for statistical\npurposes, in above terms

ITA 175/RJT/2024[2024-25]Status: DisposedITAT Rajkot28 Mar 2025AY 2024-25
Section 80GSection 80G(5)Section 80G(5)(iii)

absurd and unreasonable to apply\nsection 52(2) according to its strict literal construction. We must, therefore, eschew\nliteralness in the interpretation of section 52(2) and try to arrive at an interpretation which\navoids this absurdity and mischief and makes the provision rational and sensible, unless of\ncourse

KRUPA VILAS GAU SEVA TRUST,KUTCH vs. CIT(EXEMPTION), AHMEDABAD

Appeals of the assessee are allowed for\nstatistical purposes

ITA 163/RJT/2024[NA]Status: DisposedITAT Rajkot24 Mar 2025
Section 12ASection 12A(1)(ac)Section 80G(5)

price by more than 15 per\ncent. Many other similar situations can be contemplated where it would be absurd and\nunreasonable to apply section 52(2) according to its strict literal construction. We must,\ntherefore, eschew literalness in the interpretation of section 52(2) and try to arrive

KRUPA VILAS GAU SEVA TRUST,KUTCH vs. CIT(EXEMPTION), AHMEDABAD

Appeals of the assessee are allowed for statistical purposes

ITA 162/RJT/2024[NA]Status: DisposedITAT Rajkot24 Mar 2025

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 162/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing)

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Sanjay Punglia, CIT DR
Section 12ASection 12A(1)(ac)Section 80G(5)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

HARISH JAIN,KOTA vs. ACIT CENTRAL CIRCLE-2, KOTA, KOTA

ITA 624/JPR/2024[2014-15]Status: DisposedITAT Jaipur26 Dec 2024AY 2014-15
For Appellant: Shri Mahendra Gargieya, Adv. &For Respondent: Shri Arvind Kumar, CIT
Section 153ASection 153DSection 234A

Varghese v. ITO [1981] 7 Taxman 13/131 ITR 597 (SC) it\nwas held by Hon'ble apex court:\n“Since literal interpretation of section 52(2) leads to manifestly\nunreasonable and absurd consequences, the same should be construed\nhaving regard to the object and purpose for which it has been ... value of the\nconsideration for the transfer is correctly declared by the assessee.\nAccordingly, if the revenue seeks to bring a case within section 52(2), it\nmust show not only that the fair market value of the capital asset as on\nthe date of the transfer exceeds the full

SANATANA DHARMA VIDYASALA,ALAPPUZHA vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), KOCHI, KOCHI

In the result, appeal of the assessee is allowed for statistical purpose

ITA 279/COCH/2024[2024-25]Status: DisposedITAT Cochin25 Sept 2024AY 2024-25

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: Shri Dr. S. Pandian, CIT-DR
Section 12A(1)(ac)Section 80GSection 80G(5)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

SANATANA DHARMA EDUCATIONAL AND CULTURAL SOCIETY,ALAPPUZHA vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), KOCHI, KOCHI

In the result, appeal of the assessee is allowed for statistical purpose

ITA 278/COCH/2024[2024-25]Status: DisposedITAT Cochin25 Sept 2024AY 2024-25

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: Shri Dr. S. Pandian, CIT-DR
Section 12A(1)(ac)Section 80GSection 80G(5)

price by more than 15 per cent. Many other similar situations can be contemplated where it would be absurd and unreasonable to apply section 52(2) according to its strict literal construction. We must, therefore, eschew literalness in the interpretation of section 52(2) and try to arrive

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