VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Trust or Commission (by whatever name called) will require similar consideration-i.e., whether it is at cost with a nominal mark- up or significantly higher, to determine if it falls within the mischief of "commercial activity. However, in the case of such notified bodies, there is no quantified limit in Section 10(46). Therefore, the Central Government would have

JT.CIT(E),CIRCLE -2 AHMEDABAD, AHMEDABAD vs. VADODARA URBAN DEVELOPMENT AUTHORITY , VADODARA

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Trust or Commission (by whatever name called) will require similar consideration-i.e., whether it is at cost with a nominal mark- up or significantly higher, to determine if it falls within the mischief of "commercial activity. However, in the case of such notified bodies, there is no quantified limit in Section 10(46). Therefore, the Central Government would have

VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Trust or Commission (by whatever name called) will require similar consideration-i.e., whether it is at cost with a nominal mark- up or significantly higher, to determine if it falls within the mischief of "commercial activity. However, in the case of such notified bodies, there is no quantified limit in Section 10(46). Therefore, the Central Government would have

JT.CIT(E), CIRCLE-2 AHMEDABAD, AHMEDABAD vs. VADODARA URBAN DEVELOPMENT AUTHORITY , VADODARA

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Trust or Commission (by whatever name called) will require similar consideration-i.e., whether it is at cost with a nominal mark- up or significantly higher, to determine if it falls within the mischief of "commercial activity. However, in the case of such notified bodies, there is no quantified limit in Section 10(46). Therefore, the Central Government would have

VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Trust or Commission (by whatever name called) will require similar consideration-i.e., whether it is at cost with a nominal mark- up or significantly higher, to determine if it falls within the mischief of "commercial activity. However, in the case of such notified bodies, there is no quantified limit in Section 10(46). Therefore, the Central Government would have

THE DCIT (EXEMPTIONS) CIRCLE-2, AHMEDABAD vs. SHREE KHODAL DHAM TRUST, KAGWAD, RAJKOT

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

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedअपील सं./Ita No.904/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2014-2015 D.C.I.T.(Exemptions) Shree Khodal Dham Trust, Circle-2, Vs. Kagwad, Ahmedabad. Alka Society, 4Th Floor, Shri Sardar Patel Bhavan, Near Water Tank, Rajkot-360004. Pan: Aajts1017J

10(23C)(vi} and exemption under section 11 to assessee was unjustified - Held, yes [Paras 29 to 31 and 33] [In favour of assessee]" 8.2 In view of the above, the appellant trust is eligible for benefits of section 11 of the I T Act, as there is no violation of Section 11(5) and thus provisions of Section 13fl

THE ACIT,(E) CIRCLE-1, AHMEDABAD vs. RAI UNIVERSITY, AHMEDABAD

In the result, the appeal of the Revenue is dismissed; whereas the appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Years : 2014-15 Rai University, Asst. Commissioner Of 398-400-401-403, Vs Income-Tax (E), Village : Saroda, Taluka : Dholka, Circle-1, Ahmedabad – 382260 Ahmedabad Pan : Aabar 4376 A Assessment Years : 2014-15 Asst. Commissioner Of Rai University, Income-Tax (E), Vs Village : Saroda, Circle-1, Taluka : Dholka, Ahmedabad Ahmedabad – 382260 Pan : Aabar 4376 A अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Smt. Arti Shah, Ar Revenue By : Shri C.S. Sharma, Sr. Dr & Shri Anshu Prakas, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 14/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 22/02/2022 आदेश / O R D E R Per P.M. Jagtap, Vice-: These Two Appeals, One Filed By The Assessee Being Ita No.386/Ahd/2019 & Other Filed By The Revenue Being

34,425/- Com Rs. 1700+ 12.50% Tax each purchased for Assocham functions at Hydrabad as per bill No. 0329 dt. 27/01/2014 enclosed. ITA Nos. 386/Ahd/2019 & 553/Ahd/2019 Assessee : Rai University : AY : 2014-15 6 23. Vinay Rai AEPC Card Being amt of hotel stay charges 95,074/- No. 3769- for Ms. J. Panda & Mrs. Usha 161139-51001. Aggrawal during visit

RAI UNIVERSITY,AHMEDABAD vs. ACIT,(E) CIRCLE-1, AHMEDABAD

In the result, the appeal of the Revenue is dismissed; whereas the appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Years : 2014-15 Rai University, Asst. Commissioner Of 398-400-401-403, Vs Income-Tax (E), Village : Saroda, Taluka : Dholka, Circle-1, Ahmedabad – 382260 Ahmedabad Pan : Aabar 4376 A Assessment Years : 2014-15 Asst. Commissioner Of Rai University, Income-Tax (E), Vs Village : Saroda, Circle-1, Taluka : Dholka, Ahmedabad Ahmedabad – 382260 Pan : Aabar 4376 A अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Smt. Arti Shah, Ar Revenue By : Shri C.S. Sharma, Sr. Dr & Shri Anshu Prakas, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 14/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 22/02/2022 आदेश / O R D E R Per P.M. Jagtap, Vice-: These Two Appeals, One Filed By The Assessee Being Ita No.386/Ahd/2019 & Other Filed By The Revenue Being

34,425/- Com Rs. 1700+ 12.50% Tax each purchased for Assocham functions at Hydrabad as per bill No. 0329 dt. 27/01/2014 enclosed. ITA Nos. 386/Ahd/2019 & 553/Ahd/2019 Assessee : Rai University : AY : 2014-15 6 23. Vinay Rai AEPC Card Being amt of hotel stay charges 95,074/- No. 3769- for Ms. J. Panda & Mrs. Usha 161139-51001. Aggrawal during visit

ROTARY INTERNATIONAL DISTRICT 3054 CHARITABLE TRUST ,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

34, World Business House, Near Parimal Garden, Ellisbridge, Ahmedabad-380006 PAN: AAETR1710L (Respondent) (Appellant) Assessee Represented: Shri Anil Kshatriya, Advocate Revenue Represented: Shri Sudhendu Das, CIT-DR Date of hearing : 27-08-2024 Date of pronouncement : 26-11-2024 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal is filed by the Assessee as against the denial of registration

THE DY. CIT (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. UTTHAN SEWA TRUST,, AHMEDABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad)

10,927/- for disallowing the depreciation and Rs. 2,59,85,896/- for disallowing the benefit of deficit for early years against the income of subsequent year. 4. Thereafter assessee preferred first statutory appeal before the ld. CIT(A) who granted relief to the assessee with following observation: 5.2 I have carefully considered rival contentions and observations made

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

trust engaged in running as many as eight medical colleges and nine medical hospitals in the State of Gujarat and is largely financed by the State Government. The Hon’ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Ors. [(1987) 167 ITR 471 (SC)] has held that a liberal ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

trust engaged in running as many as eight medical colleges and nine medical hospitals in the State of Gujarat and is largely financed by the State Government. The Hon’ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Ors. [(1987) 167 ITR 471 (SC)] has held that a liberal ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

trust engaged in running as many as eight medical colleges and nine medical hospitals in the State of Gujarat and is largely financed by the State Government. The Hon’ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Ors. [(1987) 167 ITR 471 (SC)] has held that a liberal ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

trust engaged in running as many as eight medical colleges and nine medical hospitals in the State of Gujarat and is largely financed by the State Government. The Hon’ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Ors. [(1987) 167 ITR 471 (SC)] has held that a liberal ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

trust engaged in running as many as eight medical colleges and nine medical hospitals in the State of Gujarat and is largely financed by the State Government. The Hon’ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Ors. [(1987) 167 ITR 471 (SC)] has held that a liberal ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research

THE JT. CIT(EXEMPTION)(OSD), CIRCLE-2, AHMEDABAD vs. DIVYA JYOTI TRUST, SURAT

In the result, appeal of the Revenue is dismissed

Bench: S/Shri Waseem Ahmed & T.R. Senthil Kumarassessment Year : 2015-16 Jt.Cit (Exemptions)(Osd) Divya Jyoti Trust Cir.2, Ahmedabad. Vs Tejas Eye Hospital Suthar Faliyaat & Post – Mandvi Surat 394 610. Pan : Aabtd 3401 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ketan Jagirdar, Ar Revenue By : Shri Urjit Shah, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 17/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 25/02/2022 आदेश/O R D E R Per T.R. Senthil Kumar: This Appeal Is Filed By The Revenue Against Order Dated 7.6.2019 In Appeal No. Cit(A)-9/10321/Dcit(E), Cir.2-/17-18Passed By The Ld.Commissioner Of Income-Tax (Appeals)-9, Ahmedabad [For Short “Ld.Cit(A)] Relating To The Assessment Year 2015-16. 2. Revenue Has Raised The Following Grounds Of Appeal:

34,79,628/- (Rs.5,39,17,614/- minus Rs.3,04,37,986/-). The assessee replied that the assessee-trust has received corpus donation of Rs.2,68,45,899/-, and out of that an amount of Rs.2,51,85,640/- was utilized for the objects of hospital construction, equipments and other capital expenditure. According to the AO, as per the provision

THE ACIT, CIRCLE-6(1),, AHMEDABAD vs. ARMEE INFOTECH,, AHMEDABAD

In the result, ITA No.1778/Ahd/2016 (by Revenue) is dismissed, and ITA No

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No.1778/Ahd/2016 "नधा"रण वष"/Asstt. Year: 2012-13 Acit,Cir.6(1), Vs. Armee Infotech Ahmedabad. 1002, Akik Building Opp: Rajpath Club, Sg Highway, Ahmedabad 380 0054. Pan : Aaifa 4964 D

10 at 17% of the alleged bogus purchase. The ld.CIT(A) has made reference to the GP percentage shown by the assessee in the different assessment years. But while working out 17%, he has nowhere referred wither it is net profit of Rs.3.48 crores or GP out of this. GP has been shown by the assessee at 14.35% in this

M/S. ARMEE INFOTECH,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-3(3),, AHMEDABAD

In the result, ITA No.1778/Ahd/2016 (by Revenue) is dismissed, and ITA No

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No.1778/Ahd/2016 "नधा"रण वष"/Asstt. Year: 2012-13 Acit,Cir.6(1), Vs. Armee Infotech Ahmedabad. 1002, Akik Building Opp: Rajpath Club, Sg Highway, Ahmedabad 380 0054. Pan : Aaifa 4964 D

10 at 17% of the alleged bogus purchase. The ld.CIT(A) has made reference to the GP percentage shown by the assessee in the different assessment years. But while working out 17%, he has nowhere referred wither it is net profit of Rs.3.48 crores or GP out of this. GP has been shown by the assessee at 14.35% in this

VINAYAKA EDUCATION TRUST,NADIAD vs. THE DDIT, CPC, BENGALURU JURIS. AO- THE ITO, EXEMPTION WARD, VADODARA

In the result, the appeal of the assessee stands allowed

34,360/-.\nITA 1402/Ahd/2025\nAsst. Year: 2021-22\n2\n2. Facts of the Case\n2.1 The brief factual background of the case, as emanating from the\nassessment records and the orders of the lower authorities, is that the\nassessee, a charitable trust registered under section 12A of the Act since\n05.01.2011, filed its return of income for the Assessment Year