“section 115BBC”

Charitable TrustsSection 115BBCSection 115BBC150 judgments

The decision most relied on for section 115BBC is S.R.M.M.C.T.M Tiruppani Trust v. CIT (230 ITR 636), cited in 54 judgments on BharatTax.

Leading authorities on section 115BBC

S.R.M.M.C.T.M Tiruppani Trust v. CIT

230 ITR 636 · 1998 · Supreme Court

citing judgments

Capital expenditure incurred by a trust from its own funds is considered an application of income, entitling the trust to claim exemption under Section 11(1) of the Income-tax Act.

L. Hazarimal Kuthalia v. ITO

41 ITR 12 · 1961 · Supreme Court

citing judgments

The exercise of a power must be referable to a jurisdiction that validates it, not one that would render it nugatory. Provisions concerning the machinery for assessment must be interpreted to make the tax charge effective.

IT v. Andhra Pradesh Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT

225 ITR 1010 · 1997 · Supreme Court

citing judgments

For funds to be considered part of a charitable activity, the predominant object of the institution must be charitable, not profit-making. Any surplus generated must be redeployed in charitable activities.

Welham Boys' School Society v. CBDT

285 ITR 74 · 2006 · High Court

citing judgments

An order passed by the CIT under Section 12A of the Income Tax Act is quasi-judicial. Until October 1, 2004, there was no express provision in the Act for the CIT to cancel a registration certificate once granted.

CIT v. Halai Namon Association (

330 ITR 24 · 2011 · High Court

citing judgments

Profits generated from activities for the advancement of a general public utility (GPU) do not automatically qualify for exemption under Section 11 if the GPU is carried on as a business. Even if business profits are reinvested into charitable activities, the exemption under Section 11 will not be available.

Director of Income-tax v. Garden City Educational Trust

330 ITR 480 · 2011 · High Court

citing judgments

A trust with education as an object, which qualifies as a charitable purpose under section 2(15), should be accepted as having a charitable purpose. The grant of registration under section 12A is applicable when a trust has education as an object.

CIT v. Surya Educational & Charitable Trust

15 Taxmann.com 123 · 2011 · High Court

citing judgments

At the stage of registration under Section 12AA, the extent and nature of activities are not required to be examined; this is to be examined during assessment proceedings.

Isha Beevi v. TRO

101 ITR 449 · 1975 · Supreme Court

citing judgments

An error in mentioning the specific sub-section of a law, or referencing a wrong section, does not invalidate an action if the authority otherwise possesses the power to take that action.

Judgments citing section 115BBC

DCIT, Central Circle-1(4), Kolkata vs. Uttarayan Trust for Education & Social Welfare, Cooch Behar

In the result, the appeal of the revenue is dismissed

ITA 2563/KOL/2024[2016-17]Status: DisposedITAT Kolkata08 Dec 2025AY 2016-17

Bench: SHRI SONJOY SARMA (Judicial Member)

For Appellant: Shri S R Nag, ARFor Respondent: Shri Manoj Kr. Patil, JCIT, Sr. DR

Section 115BSection 127Section 131Section 133ASection 143(2)Section 147Section 148Section 250

आयकर अपील"य अ"धकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH KOLKATA SHRI RAJESH KUMAR

ACIT, Chennai vs. Sri Balaji Educational Amd Trust Charitable Public Trust, Chenna

In the result, the appeal of the Assessee and that of the Department are dismissed

ITA 1471/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250

आयकर अपीलीय अिधकरण, ‘ए’ "ायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी एबी टी वक", "ाियक

M/S. Sri Balaji Educational and Charitable Public Trust, Chennai vs. ACIT, Central Circle-3(4), Chennai

In the result, the appeal of the Assessee and that of the Department are dismissed

ITA 1249/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250

आयकर अपीलीय अिधकरण, ‘ए’ "ायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी एबी टी वक", "ाियक

Narayani Siddhar Peedam Charitable Trust, Vellore vs. DDIT (Exemptions-III), Chennai

ITA 1532/CHNY/2025[2011-12]Status: DisposedITAT Chennai26 Nov 2025AY 2011-12

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 1532/Chny/2025 निर्धारण वर्ष/Assessment Year: 2011-12 Shri Narayani Siddhar Peedam Charitable Trust, Rep. By Trustee, K. Soundararajan, Thirumalaikodi, Ariyur Village, Vellore 632 055. Pan: Aaatn 3254F (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement The Deputy Director Of Vs. Income Tax, (Exemptions – Iii) Chennai (प्रत्यर्थी/Respondent) : Shri N. Muralikumaran, Sr. Advocate : Ms. Mythili, Jcit : 25.11.2025 : 26.11.2025 आदेश/Order Per George George K: This Appeal Filed By The Assessee Is Directed Against The Order Of Addl/Jcit(A)-5, Mumbai Dated 29.03.2025, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act'). The Relevant Assessment Year Is 2011-12. :- 2 -:

Section 115BSection 12ASection 143(2)Section 143(3)Section 250Section 80G(5)(vi)

evidence to be maintained ant adduced by the Assessee u/s 115BBC of the Income Tax Act. C. The object of sub-section (i) of section 115BBC(1) was neither understood nor applied thy the Assessing Officer as well as the CIT Appeals D. The Assessing Officer as well ... Calcutta High Court is in context of burden of proof u/s.68 of the Act and does not have the application of provisions of section 115BBC of the Act. 8. The Delhi Bench of the Tribunal in the case of Sunder Deep Educational Society vs. ACIT in ITA No.2428/Del/2011 (order dated

Sri Gowri Sankara Sagara (Uppara) Anna Sathra Sangham, Kurnool vs. ITO., Exemption Ward, Hyderabad

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

ITA 1507/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Nov 2025AY 2018-19

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

voluntary contributions, failing which the A.O. proposed to treat the entire voluntary contributions of Rs. 1,06,98,759/- as anonymous donations under Section 115BBC of the Act, for which there was no response form the assessee. 6 Sri Gowri Sankara Sagara (Uppara) Anna Sathra Sangham, Srisailam ... Income Tax Act, 1961 and treated the entire voluntary contributions of Rs. 1,06,98,759/- as anonymous donations under Section 115BBC of the Act and brought the same to tax and thus assessed the total income of the assessee at Rs. 1,06,98,759/-. 8. Aggrieved

Menaba Charitable Trust, Ahmedabad vs. The ITO, Ward-1(Exemptions), Ahmedabad

ITA 1361/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1361/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 Menaba Charitable Trust The Ito बनाम/ 26, Mahavir Jain Soc., Ward-1 (Exemptions) V/S. Bapunagar Ahmedabad – 380 015 Ahmedabad – 380 024 "थायी लेखा सं./Pan: Aaatm 2171 N (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rushin Patel, Ar Revenue By : Shri C Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 24/12/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-2018. 2. The Assessee Raised The Following Grounds Of Appeal:

For Appellant: Shri Rushin Patel, ARFor Respondent: Shri C Dharani Nath, Sr.DR

Section 11Section 115BSection 250

making the addition of Rs.32,74,493/- to the total income of the appellant on account of treating donations as the 'anonymous donation' under section 115BBC of the Income Tax Act. 1.3 That the learned assessing officer has erred in making the addition on account of anonymous donation' despite ... fact that appellant has satisfactorily proved the identity of donors as referred under section 115BBC of the Income Tax Act, 1961 by providing the details of the name, address, mode of payment of donation etc. 1.4 That the learned assessing officer has erred to consider that

Nir Ideal Home for Mentally Retarded and Associated Disability, Haroa vs. ITO, Ward 1(1), Exempt, Kolkata

Accordingly the grounds raised by the appellant in this regard are dismissed”

ITA 1376/KOL/2025[2022-2023]Status: DisposedITAT Kolkata30 Oct 2025AY 2022-2023

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1376/Kol/2025 Assessment Year: 2022-2023 Nir Ideal Home For Mentally Retarded & Associated Disability,………………..……Appellant Vill. Pilkhana, Haroa, North 24-Parganas-743425, West Bengal [Pan:Aaaan3642G] -Vs.- Income Tax Officer,……………………………....Respondent Ward-1(1), Exemption, Kolkata, (Assessment Unit, Income Tax Department), Income Tax Building, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri Arvind Agrawal, A.R., Appeared On Behalf Of The Assessee Shri Mrinmay Basak, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: August 28, 2025 Date Of Pronouncing The Order: October 30, 2025 O R D E R

Section 115BSection 143(2)Section 80G

appellant claimed that the anonymous donation received during the year under consideration of Rs.17,65,436/- should not be treated as violation of section 115BBC as the Trust comes under the exceptional category of it. The appellant vide its reply self-proclaimed itself as a mixed purpose Trust ... Assessing Officer brought the anonymous donations of Rs.17,65,436/- received during the year under consideration to tax as per the provisions of section 115BBC of the Act for the AY 2022-23. On being aggrieved, the appellant-assessee preferred an appeal before the ld. CIT(Appeals

Lakshmiammal Progressive Educational Trust, Komarapalayam vs. The Income Tax Officer, Exmeptions, Salem

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

ITA 2193/CHNY/2025[2018-19]Status: DisposedITAT Chennai30 Oct 2025AY 2018-19

Bench: Shri George George K

For Appellant: Shri S.R. Srikrishna, CAFor Respondent: Ms. V. Supraja, Addl.CIT

Section 11Section 115BSection 12ASection 143(3)Section 250

आयकर अपीलीय अिधकरण, ‘ए’ (एस एम सी), "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ (SMC) BENCH, CHENNAI

Kailash Gahlot, New Delhi vs. DCIT, Central Circle-4, New Delhi

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

ITA 3431/DEL/2023[2015-16]Status: DisposedITAT Delhi24 Oct 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.3431/Del./2023, A.Y. 2015-16 Kailash Gahlot Deputy Commissioner Of C-6/6172, Vasant Kunj, Income Tax, New Delhi Vs. Central Circle-4, Pan: Aajpg2849N New Delhi (Appellant) (Respondent) Appellant By Sh. Vinod Kumar Bindal, Ca Sh. Anmol Jha, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 24/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2015-16 Is Directed Against The Order Dated 30.09.2023 Of The Commissioner Of Income Tax (Appeals)-23, New Delhi [‘Cit(A)’].

Section 115BSection 132(4)Section 153DSection 69C

mechanical approval under Section 153D of the Act without due application of mind. Para no. 11 of the order mentions that charging tax under Section 115BBC of the Act whereas the additional tax liability was applicable w.e.f. assessment year 2017-18 was not attracted. The above-said arguments inadvertently escaped

Shri Mahaveer Charitable Trust, Allahabad vs. ITO(Exemption), Allahabad

In the result, the appeal of the assessee is partly allowed

ITA 181/ALLD/2024[2013-14]Status: DisposedITAT Allahabad14 Oct 2025AY 2013-14

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2013-14 Shri Mahaveer Charitable Trust, Vs Income Tax Officer 46, Rajendra Nagar, Baluaghat, (Exemption), Allahabad Allahabad-211003, U.P. Pan: Aahts9123K (Appellant) (Respondent) Assessee By: Dr. Pawan Jaiswal & Sh. Ajit Kumar, Advocates Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 22.07.2025 Date Of 14.10.2025 Pronouncement: O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit, Nfac Dated 28.09.2024, Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee That Was Filed Against The Orders Of The Income Tax Officer (Exemption), Allahabad Dated 30.03.2018. The Grounds Of Appeal Are As Under: - “1. Because The Impugned Order Of The Ld. Cit(A) Dated 28.09.2024 Affirming The Addition Of Rs. 1,97,69,650/- On Account Of Donation Received & Rejection Of The Submissions Of The Appellant That Appeal Proceedings Pending Against The Order Passed Under Section 143(3) Dated 30.03.2016 Are Infructuous Is Absolutely Illegal & Against The Principles Of Law. 2. Because The Hon'Ble Supreme Court In The Case Of Cit V. Alagendran Finance Ltd. [27.07.2007] Had Observed That When An Order Of Assessment Is Reopened, The Previous Assessment Will Be Held To Be Set Aside & The Whole Proceedings Would Start Afresh & In The Case In Hands The Assessment Order Dated 30.03.2016 Has Been Set-Aside By The Then Incumbent Ld. Cit(E); That Is To Say That No Assessment Existed On The Date When Order Dated 28.02.2018 Under Section 263 Of The Act Was Passed By The Then Incumbent Cit(E). 3. Because Section 263 Of The Act Grants Power To The Jurisdictional Commissioner To Direct For Revision Of Orders & Reads As Under (Relevant Statute Quoted):

For Appellant: Dr. Pawan Jaiswal & Sh. Ajit Kumar, AdvocatesFor Respondent: Sh. A.K. Singh, Sr. DR

Section 143(3)Section 263

income of rupees Nil. However, the donations of Rs.1,97,69,650/-. were treated as anonymous donations and therefore, were brought to tax under section 115BBC of the Income Tax Act, 1961. 3. Being aggrieved by the said assessment order, the assessee filed an appeal before ... Exemption) had further observed that even though the anonymous donations amounting to Rs. 1,97,69,650/- had been charged to tax under section 115BBC, the interest under section 234A and 234B had not been charged. The ld. Sr. DR pointed out that this order under section

S K N Sikshan Sansthan, Bhadhadhar vs. Dy. Commissioner Income Tax (Central)-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 445/JPR/2025[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

Bench: Shri Gagan Goyal & Shri Narinder Kumarskn Shikshan Sansthan, 1, N. H. 11 Bhadhadar Sikar 332 315 Pan No.: Aamts 1103L ...... Appellant Vs.

For Appellant: Mr. Shafi Mohammad, Adv., Ld. ARFor Respondent: Mr. Gautam Singh Choudhary, Addl. CIT

Section 10Section 115BSection 12ASection 143(3)Section 147Section 148Section 250Section 57

IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCH “SMC”, JAIPUR BEFORE SHRI GAGAN GOYAL, ACCOUNTANT MEMBER AND SHRI NARINDER KUMAR

Aryans Educational and Charitable Trust Regd, Mohali vs. Commissioner of Income Tax, Exemptions, Chandigarh

In the result, appeal is allowed

ITA 1136/CHANDI/2024[2025-26]Status: DisposedITAT Chandigarh24 Sept 2025AY 2025-26

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1136/Chd/2024 "नधा"रण वष" / Assessment Year: 2025-26 Aryans Educational & The Cit (Exemptions), Charitable Trust, Regd.Mohali Vs Chandigarh, C/O Shri Tej Mohan Singh, Advocate, # 527, Sector 10-D, Chandigarh. "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Tej Mohan Singh, Advocate Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 07.08.2025 Date Of Pronouncement : 24.09.2025

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Manav Bansal, CIT DR

Section 11Section 12ASection 12A(1)(ac)Section 13(1)(c)Section 13(1)(ii)Section 13(3)

Officer and such statements were made basis for disallowance of the entire amount of Rs. 1,73,73,648/- by applying the provisions of section 115BBC and section 68 of the Act treating corpus donations received from students to be anonymous donations. 8. We find that the not considering

Shree Jain Swethambar Murti Pujak Sangh, Chennai vs. ITO, Exemptions Ward-4, Chennai

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

ITA 1994/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Sept 2025AY 2019-20

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1994/Chny/2025 िनधा"रण वष"/Assessment Year:2019-20 M/S. Shree Jain Swethambar The Income Tax Officer, Murti Pujak Sangh, Vs. Exemptions Ward 4, 55, Thirumalai Raja Puram, Chennai. Avadi, Chennai – 600 054. Pan: Aagts 7268G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Hitesh, Advocate For Shri D. Anand, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 17.09.2025 घोषणा क" तारीख/Date Of Pronouncement : 17.09.2025

For Appellant: Shri Hitesh, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 250

आयकर अपील"य अ"धकरण, ‘बी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी जॉज" जॉज

DCIT Central Circle-06, New Delhi vs. Santosh Trust, New Delhi

ITA 1427/DEL/2023[2017-18]Status: DisposedITAT Delhi29 Aug 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Suresh K. Gupta, AdvFor Respondent: Sh. Mahesh Shah, CIT, DR

Section 12ASection 133(6)Section 142(1)Section 143(2)Section 143(3)Section 69ASection 80G(5)(iv)

aggregate income of Rs.91.07 Crore is the income which does not partake character of anonymous donation /s 115BBC of the Act. As per section 115BBC(1), if any institution, trust, university covered w/s 10(23C)(iiiad), or 10(23C)(vi), or 10(23C)(iiiae ... donations exceeding Rs.1 lakh or 5% of total donation (whichever is higher). Since, having regard to the facts on record, the provisions of section 115BBC (1) will not apply in the present case of trust created or established wholly for religious purposes. VI. In the decisions of Hon'ble Allahabad

Sangamner Medical Foundation and Research Institute, Ahmednagar vs. Exemption Circle Aurangabad, Ahmednagar

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

ITA 900/PUN/2025[2018-19]Status: DisposedITAT Pune26 Aug 2025AY 2018-19

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

For Appellant: Shri Suhas BoraFor Respondent: Shri Akhilesh Srivastva

Section 115BSection 12ASection 133(6)Section 142(1)Section 143(2)Section 143(3)Section 80Section 80G

register maintained by the appellant trust. 4. The Ld. CIT(A) erred in confirming the action of the Ld. AO invoking the provisions of section 115BBC without bringing on record any material to treat the donation as anonymous donations. 5. The Ld. CIT(A) as well ... No.900/PUN/2025, AY 2018-19 assessee and accordingly made an addition amounting to Rs.2,12,97,163/- on account of anonymous donations under section 115BBC of the Act vide his order dated 021.03.2021 passed under section 143(3) r.w.s.143(3A) & 143(3B) of the Act. 4. Aggrieved by the assessment order

Nathoo Lalji Charity Trust, Mumbai vs. Income Tax Officer, Exem. Ward 2(1), Mumbai

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

ITA 3925/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Aug 2025AY 2019-20

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Satyaprakash R.Singh, CIT DR

Section 11Section 115BSection 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Nathoo Lalji Charity Trust, Mumbai vs. Income Tax Officer, Exem. Ward 2(1), Mumbai

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

ITA 3924/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Satyaprakash R.Singh, CIT DR

Section 11Section 115BSection 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Nathoo Lalji Charity Trust, Mumbai vs. Income Tax Officer, Exem. Ward 2(1), Mumbai

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

ITA 3923/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Satyaprakash R.Singh, CIT DR

Section 11Section 115BSection 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Nathoo Lalji Charity Trust, Mumbai vs. Income Tax Officer, Exem. Ward 2(1), Mumbai

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

ITA 3907/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Aug 2025AY 2019-20

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Satyaprakash R.Singh, CIT DR

Section 11Section 115BSection 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Income Tax Officer, Exemptions Ward, Trichy vs. Arulmigu Swaminatha Swami Thirukkovil, Kumbakonam

In the result, the appeals filed by the revenue in ITA Nos

ITA 370/CHNY/2025[2013]Status: DisposedITAT Chennai30 Jul 2025

Bench: Shri S.S.Viswanethra Ravi & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 370 & 368/Chny/2025 & Co Nos.32 & 33/Chny/2025 (In Ita Nos.: 370 & 368/Chny/2025) धनिाारण वर्ा / Assessment Year: 2013-14 & 2014-15 Income Tax Officer, Arulmigu Swaminatha Swami Exemptions Ward, Trichy, Thirukkovil, Vs. The Executive Officer, Swamimalai, Kumbakonam – 612 301. [Pan: Aaata-6446-J] (अपीलाथी/Appellant) (Respondent/Cross Objector) अपीलाथीकीओरसे/ Appellant By : Shri. P. Krishna Kumar, J.C.I.T. प्रत्यथीकीओरसे/Respondent By : Shri. N. Arjun Raj, Advocate सुनवाई की तारीख/Date Of Hearing : 09.05.2025 घोर्णा की तारीख/Date Of Pronouncement : 30.07.2025 आदेश /O R D E R Per Bench: These Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Are Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Years 2013-14 & 2014-15, Vide Order Dated 20.12.2024. Since The Facts Are Identical & Issues Are Common, Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Were Heard & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri. P. Krishna Kumar, J.C.I.TFor Respondent: Shri. N. Arjun Raj, Advocate

Section 10Section 11Section 12A(1)(b)Section 139Section 139(1)Section 147

would be outside the scope of the charging provisions of the Act especially considering the exceptions carved out in the provisions in Section 115BBC of the Act for the institution created wholly for religious purposes. 23. The preliminary issue raised by the Revenue is on the validity of tax exemption