AIA ENGIONEERING LTD.,AHMEDABAD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, AHMEDABAD-1, AHMEDABAD

In the result, the appeals filed by the assessee are hereby allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

charitable trusts which were duly registered under section 80G(5)(vi), assessee was entitled to claim deduction under section 80G in respect of such contribution - Held, yes - Whether since action of Assessing Officer in allowing claim under section 80G was a plausible view, impugned invocation of revision jurisdiction under section 263 was unjustified-Held, yes [Para 23] [In favour

TORRENT POWER GRID LIMITED,AHMEDABAD vs. THE PR.CIT-3, AHMEDABAD

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

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

charitable trusts which were duly registered under section 80G(5)(vi), assessee was entitled to claim deduction under section 80G in respect of such contribution - Held, yes - Whether since action of Assessing Officer in allowing claim under section 80G was a plausible view, impugned invocation of revision jurisdiction under section 263 was unjustified-Held, yes [Para 23] [In favour

VIMAL COAL PVT.LTD.,AHMEDABAD vs. THE DY.CIT., CIRCLE-4(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

135 of the Companies Act, 2013. Out of this, the\nassessee claimed Rs.11,02,500/- (i.e., 50%) as deduction under section 80G of\nthe Act. The AO disallowed the claim stating that since CSR expenditure is\nmandatory and not voluntary, it is not eligible for deduction under section\n80G. Reliance was placed on Explanation 2 to section

SHREE FOFARIA CHARITABLE FAMILY TRUST,VADODARA vs. THE CIT(EXEMPTION), AHMEDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

Charitable Trust vs. CIT(E) Asst. Year –N.A. - 2– On the plea that your appellant has filed an application under clause (ii) and not under clause (iii) of first proviso to section 80G(5) Act as you appellant was holding provisional approval of registration. 1.02 Your appellant submits that due to technical glitches, the income tax portal wa not allowing

ITO(E),VADODARA, RACE CIURSE VADODARA vs. TAKSHSHILA FOUNDATION(NGO), KARELIBAUGH, VADODARA

In the result, the Cross Objection filed by the assessee is allowed, whereas the appeal filed by the Revenue is dismissed as infructuous

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar, Accountnat Member & Co No.8/Ahd/2024 (In Ita No.118/Ahd/2024 – By Assessee) Assessment Year : 2022-23 The Income Tax Officer (E) Takshshila Foundation (Ngo) (Ward) Vs B/15, Suhas Society Race Course Harni Road Vadodara 390 007 Karelibaug, Vadodara – 390 018 (Gujarat) Pan:Aaatt 5363 K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent & Cross Objector) Assessee By : Shri D.K. Parikh, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 25/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 02/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal By The Revenue Arises From The Order Of The Office Of Commissioner Of Income Tax (Appeals), Addl/Jcit (A)–6, Chennai [Hereinafter Referred To As "Cit(A)"] Dated 08-12-2023, For The Assessment Year (Ay) 2022-23 Against The Intimation/Order Passed U/S. 143(1) Of The Income Tax Act, 1961 (“The Act” In Short) By Cpc, Bengaluru & The Assessee Is In Cross Objection Thereof.

Charitable Trust v. Income-tax Officer. (Exemption) [2021] 125 taxmann.com 75 (Gujarat). 4.3.6 In view of the above discussion, I am of the view that the assessing officer erred in not allowing deduction to the appellant/assessee for the amount accumulated under the provisions of section 11 of the Income-tax Act, 1961. It was merely a procedural lapse on part

NIRAKAR TRUST,VADODARA vs. THE CIT(EXEMPTION), AHMEDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : - Nirakar Trust Cit(Exemption) 11, Anandsagar Apartment Vejalpur Anand Sagar Society Ahmedabad. Jetalpur Road Vadodara 390 007 Pan : Aabtn 8200 G (Applicant) (Responent) : Shri Viranch Modi, Ca Assessee By : Shri Alpesh Parmar, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 07/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 09/10/2025 आदेश आदेश/O R D E R आदेश आदेश

135 days is condoned, and the appeal is admitted. 3. Facts of the Case 3.1 The assessee is a registered public charitable trust. The trust was earlier granted provisional approval under section

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY.CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

trust or institution established by the Central Government or a State Government, as the case may be.” 15. A plain reading of the above provision leaves no scope for any interpretational leeway. The Legislature has expressly provided that any subsidy, grant, duty drawback, waiver, concession or reimbursement “by whatever name called” constitutes income, and has simultaneously carved out only

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION - THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

trust or institution established by the Central Government or a State Government, as the case may be.” 15. A plain reading of the above provision leaves no scope for any interpretational leeway. The Legislature has expressly provided that any subsidy, grant, duty drawback, waiver, concession or reimbursement “by whatever name called” constitutes income, and has simultaneously carved out only

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

trust or institution established by the Central Government or a State Government, as the case may be.” 15. A plain reading of the above provision leaves no scope for any interpretational leeway. The Legislature has expressly provided that any subsidy, grant, duty drawback, waiver, concession or reimbursement “by whatever name called” constitutes income, and has simultaneously carved out only

DCIT CIRCLE-2(1)(1), AHMEDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

trust or institution established by the Central Government or a State Government, as the case may be.” 15. A plain reading of the above provision leaves no scope for any interpretational leeway. The Legislature has expressly provided that any subsidy, grant, duty drawback, waiver, concession or reimbursement “by whatever name called” constitutes income, and has simultaneously carved out only

DCIE CIRCLE-2(1)(1), AHEMDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

trust or institution established by the Central Government or a State Government, as the case may be.” 15. A plain reading of the above provision leaves no scope for any interpretational leeway. The Legislature has expressly provided that any subsidy, grant, duty drawback, waiver, concession or reimbursement “by whatever name called” constitutes income, and has simultaneously carved out only

DCIT, CIRCLE-2(1)(1) AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCE LIMITED SHIVARTH AMBIT, AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

trust or institution established by the Central Government or a State Government, as the case may be.” 15. A plain reading of the above provision leaves no scope for any interpretational leeway. The Legislature has expressly provided that any subsidy, grant, duty drawback, waiver, concession or reimbursement “by whatever name called” constitutes income, and has simultaneously carved out only

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

Appeal are dismissed

trust or institution\nestablished by the Central Government or a State Government, as the\ncase may be.\"\n15. A plain reading of the above provision leaves no scope for any\ninterpretational leeway. The Legislature has expressly provided that any\nsubsidy, grant, duty drawback, waiver, concession or reimbursement\n“by whatever name called” constitutes income, and has simultaneously\ncarved out only

DCIT CIRCLE-2(1)(1), AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT , BODAKDEV AHMEDABAD

Appeal are dismissed

trust or institution\nestablished by the Central Government or a State Government, as the\ncase may be.\"\n15. A plain reading of the above provision leaves no scope for any\ninterpretational leeway. The Legislature has expressly provided that any\nsubsidy, grant, duty drawback, waiver, concession or reimbursement\n“by whatever name called” constitutes income, and has simultaneously\ncarved out only

GUJARAT MINERAL DEVELOPMENT CORPORATION LIMITED,KHANJI BHAVAN vs. PR. COMMISSIONER OF INCOME TAX-1, AAYAKAR BHAWAN(VEJALPUR), AHMEDABAD

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

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2020-21

135(4)(b) of the Companies Act, 2013, as the CSR activities were routed through third- party trusts instead of being undertaken directly or through eligible implementing agencies. In the view of the PCIT, this treatment defeated the object of both the Companies Act and the Income-tax Act. The Assessing Officer had failed to examine whether the donation claimed

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 is not eligible to claim exemption u/s. 11(2) of the Act r.w.r. 17(2) and 17(3) of the I.T. Rules for accumulation for specific purposes amounting to Rs.174,00,00,000/- [however, only Rs.28,27,97,868/- remains to be set apart u/s 11(2) of the Act after reducing revenue expenditure of Rs.3,85,16,135

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 is not eligible to claim exemption u/s. 11(2) of the Act r.w.r. 17(2) and 17(3) of the I.T. Rules for accumulation for specific purposes amounting to Rs.174,00,00,000/- [however, only Rs.28,27,97,868/- remains to be set apart u/s 11(2) of the Act after reducing revenue expenditure of Rs.3,85,16,135

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 is not eligible to claim exemption u/s. 11(2) of the Act r.w.r. 17(2) and 17(3) of the I.T. Rules for accumulation for specific purposes amounting to Rs.174,00,00,000/- [however, only Rs.28,27,97,868/- remains to be set apart u/s 11(2) of the Act after reducing revenue expenditure of Rs.3,85,16,135