TRILOKNATH VATSALYA VATIKA,GANDHINAGAR vs. THE DY.CIT,CPC, BANGALORE PRESENT JAO- THE ITO, WARD-1 (EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1092/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 Triloknath Vatsalya Vatika The Dy.Cit बनाम/ At Balva Cpc Bangalore. V/S. Nr. Tahuko Hotel Present Jao Kalol The Ito Ward-1(Exemption) Gandhinagar – 382 001 Ahmedabad-380 015 "थायी लेखा सं./Pan: Aants 5604 B (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Kushal Fofaria, Ar Revenue By : Shri R.P. Rastogi, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 15/10/2025 घोषणा की तारीख /Date Of Pronouncement: 28/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal By The Assessee Is Directed Against The Order Dated 10/03/2025 Passed By The Office Of The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-Gwalior [Hereinafter Referred To As “Cit(A)”], U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), For The Assessment Year (Ay) 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:

charitable trusts must be interpreted liberally so as to advance the object of charity and not to defeat it on mere technicalities. Accordingly, we are of the considered view that the assessee trust has duly complied with the conditions prescribed under section 12A(1)(b) read with section 139

RURAL DEVELOPMENT FOUNDATION,ANAND vs. CPC, BENGALURU JURIS. AO- THE ITO, WARD-EXEMPTION, VADODARA

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.927/Ahd/2025 िनधा"रण वष" /Assessment Year : 2019-20 Rural Development Cpc, Bengaluru बनाम/ Foundation Juris.Ao – The Ito Ward- V/S. Aitc, 2Nd Floor Exemption Narayan Complex Vadodara – 390 007 Nr.Shubh Laxmi Shopping Centre Station Road Anand – 388 001 "थायी लेखा सं./Pan: Aabtr 1090 C (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Ms. Arti N. Shah, Ar Revenue By : Shri Rameshwar P. Meena, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/10/2025 घोषणा की तारीख /Date Of Pronouncement: 29/10/2025 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 21/02/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2019-2020. 2. The Assessee Has Raised The Following Grounds Of Appeal: Rural Development Foundation Vs. Cpc, Bengaluru Juris Ao The Ito, Ward-Exemption Asst. Year : 2019-20

charitable trusts must be interpreted liberally so as to advance the object of charity and not to defeat it on mere technicalities. Accordingly, we are of the considered view that the assessee trust has duly complied with the conditions prescribed under section 12A(1)(b) read with section 139

CLEAN TEETH CLEAN MOUTH CHARITABLE TRUST,RAJKOT vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

Charitable Trust vs. CIT(E) Asst.Year –N.A. - 2– 06.05.2023. The assessee / Applicant Trust had been earlier granted or for provisional approval in Form No. 10AC on 06.04.2023 under Clause (iv) of first proviso. On receipt of application, CIT(E) observed that as per provisions of Section 80G(5) as it stands from 01.04.2021, in the present case, since the assessee

KOSHAMBH CHARITABLE TRUST,VADODARA vs. CPC, BANGALORE PRESENT JURISDICTION THE ITO, EXEMPTION WARD, VADODARA

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

Charitable Trust vs. ITO(E) Asst.Year –2018-19 - 6– Tribunal held that requirement of filing Form 10/10B is merely directory in nature and failure to furnish Form 10/10B before due date prescribed under Section 139

NANA AND RANDER SUNNI VOHRA MEDICAL AND CHARITABLE TRUST,SURAT vs. COMMISSIONER OF INCOMETAX (EXEMPTION ) AHMEDABAD, AHMRDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

Charitable Trust vs. CIT(E) Asst.Year –2023-24 - 2– provisional approval in Form No. 10AC on 24.03.2023 under Clause (iv) of first proviso. On receipt of application, CIT(E) observed that as per provisions of Section 80G(5) as it stands from 01.04.2021, in the present case, since the assessee had got provisional approval under Section

AKSHAT EDUCATION AND CHARITABLE TRUST,ANAND vs. THE ITO, WARD- EXEMPTION, VADODARA

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

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.457/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-2021 Akshat Education & Charitable The Income Tax Officer, Trust, बनाम Ward (Exemption), / 5/35, Gosainu Faliyu, Vadodara. V/S. Asodar Borsad Road, Asodar, Anand-388307. (Gujarat) "थायी लेखा सं./Pan: Aaeta2211K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Mehul Thakkar, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 14/08/2025 घोषणा की तारीख /Date Of Pronouncement: 19/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Assessee Is Directed Against The Order Of The Learned Joint Commissioner Of Income Tax (Appeals)-2, Coimbatore [Hereinafter Referred To As “Ld. Cit(A)”] Dated 25.01.2025, Passed Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”] For The Assessment Year 2020–21. The Impugned Order Arises Out Of The Akshat Education & Charitable Trust Vs. Ito(E) Assessment Year 2020-21

section 139 of the Act. The income is arrived after deducting the allowable expenditures as per the I.T. Act. 1961. Akshat Education and Charitable Trust

SHRI MAHESH P. GANDHI,AHMEDABAD vs. THE ACIT., CIRCLE-10,, AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita Nos.1022 To 1025/Ahd/2018 िनधा"रण वष"/Asstt. Year: (1992-1993 To 1995-1996) Shri Mahesh P. Gandhi, A.C.I.T., D-404, 5Th Floor, Vs. Circle-10, Dharnidhar Tower, Ahmedabad. Paldi, Ahmedabad.

Charitable Trust v. Dy. CIT reported in 280 ITR 357 has held that: “3. The Supreme Court in Vedabai v. Shantaram Baburao Patil [2002] 253 ITR 798held as under: "In exercising discretion under section 5 of the Limitation Act the Courts should adopt a pragmatic approach. A distinction must be made between a case where the delay is inordinate

SHIKSHA FOUNDATION,AHMEDABAD vs. THE ITO, WARD-2 (EXEMP), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

charitable trust registered under section 12A, had substantially satisfied condition for availing benefit of exemption as a trust, it could not be denied exemption merely on bar of limitation in furnishing audit report in Form no. 10B. 7.5 In the case of CIT v. Gujarat Oil & Allied Industries201 ITR 325 (Gujarat), the High Court held that where an assessee could

SHRI MANAV VIKAS FOUNDATION,CHAMARAJ, TL. VADHAVAN vs. ITO, WARD-2(EXEMP), AHMEDABAD

In the result, the appeal of the asessee is allowed

139. Provisions of Rule 17B of IT Rules. X "[Audit report in the case of charitable or religious trusts, etc. 17B. The report of audit of the accounts of a trust or institution which is required to be furnished under sub-clause (ii) of clause (b) of sub-section

TARAMANDAL CHARITABLE TRUST,VADODARA vs. ACIT, CPC, BANGLORE

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

Charitable Trust vs. ACIT (CPC) certain incomes", if] the return is furnished beyond the due date specified under sub-section (1) of section 139

SHRI MAHAVIR GOPALAN CHARITABLE TRUST,KAPADVANJ vs. THE ITO(EXEMPTIONS) BHAVNAGAR PRESENTLY THE ITO (EXEMPTION), VADODARA

In the result, appeal filed by the assessee is allowed

charitable or religious\npurposes in India falls short of eighty-five per cent of the income\nderived during that year from property held under trust, or, as the\ncase may be, held under trust in part, by any amount—\n(i) for the reason that the whole or any part of the income has\nnot been received during that year

TATAM SEVA SANSTHAN,BHAVNAGAR vs. COMMISSIONER OF INCOME TAX, (EXEMEPTION), AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

139 taxmann.com 121 (Calcutta). Further, CIT(E) observed that CBDT on multiple occasions had extended the time line in filing the application in Form 10AB and vide Circular No. 8/2022 had extended the time line to 30.09.2022. Thereafter, another Circular No. 6/2023 dated 24.05.2023 was introduced, but in such Circular the date so far as filing of Form 10AB under

KANCHANBA EDUCATION TRUST,AHMEDABAD vs. THE AC/DCIT. CIRCLE-1, EXEMPTION, AHMEDABAD

The appeal of the assessee stands allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

Charitable Trust registered under the Bombay Public Trust Act, 1960 and also registered under section 12A of the Income-tax Act (“the Act”). The trust runs “Aim International School” and it filed its return of income for A.Y. 2024-25 on 25.09.2024 within the extended due date of 15.11.2024 declaring total income at Nil after claiming exemption under sections

SHREE HARSANIJI PUBLIC CHARITABLE TRUST,MEHSANA vs. THE ITO (EXEMPTION), PALANPUR

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

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumarassessment Year : 2015-16 Shree Harsaniji Public Charitable Trust Ito (Exemption) 32, Shiv Society Part-2 Vs Palanpur. Nr.B.K. Cinema Mehsana 384 002. Pan : Aaats 7750 B.

trust is not in doubt; b) delay is due to oversight mistake; c) trustees or the settlers have not been benefited by such failure directly or indirectly; 12. Further, Hon’ble Supreme Court in the case of CIT Vs. Nagpur Hotel Owners Association (supra) has held that it is abundantly clear from the wordings of sub-section (2) of section

HEALTH FOUNDATION & RESEARCH CENTRE,DAHOD vs. THE ACIT, CIRCLE-2, EXEMPTION, AHMEDABAD

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

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

charitable trust duly registered under section 12A of the Act since 16.04.1984 and is also enjoying approval under section 80G(5) of the Act. The trust is engaged in the field of medical relief and education and is running a hospital and nursing college. For the year under consideration, the assessee filed its return of income under section 139

INDIAN REDCROSS SOCIETY ANAND DISTRICT BRANCH,ANAND vs. THE INCOME TAX OFFICER, WARD-EXEMPTION, VADODARA

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

charitable trust for past 30 years which substantially satisfies the conditions for availing such exemption, should not be denied the same merely on the bar of limitation especially when the legislature has conferred wide discretionary powers to condone such delay. Applying the said principle, the petition is allowed. The impugned order passed by respondent dated 12.3.2021 is quashed and aside

PARANTAP CHARITABLE TRUST,VADODARA vs. THE ITO, WARD- EXEMPTION, VADODARA

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

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1697/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2017-18) बनाम Parantap Charitable Trust Income Tax Officer 421, Vraj Siddhi Tower, Ward – Exemption, / Khanderao Market Char Vadodara Vs. Rasta, Rajmahal Road, Vadodara - 390001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aactp0976E (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Rushin Patel, Ar ""यथ" क" ओर से/Respondent By : Smt. Mamta Singh, Sr. Dr 07/01/2026 Date Of Hearing Date Of Pronouncement 08/01/2026 O R D E R The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Hereinafter Referred To As “Nfac”), Delhi (Hereinafter Referred To As “Cit(A)”) Dated 15.06.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As The “Act”) & Relates To Assessment Year (A.Y.) 2017-18. 2. The Grounds Of Appeal Raised By The Assessee Are As Under:

Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2017-18. 2. The grounds of appeal raised by the assessee are as under: “1. The ld. CIT(Appeals) has erred in law and on facts of the case, in confining the direction Circular No.10/2019 in taking cognizance of Form

MAHAVIR KELAVANI MANDAL,ANTROLI vs. WARD- EXEMPTION, VADODARA

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra R. Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2016-17 Mahavir Kelavani Mandal, Vs Deputy Commissioner Of Antroli, Income-Tax, C/O. Mahavir Kelavani Mandal, Bangalore Nadiad, Gujarat – 387366 Pan: Aactm 6322 R अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Sunil Talati, Ar Revenue By : Shri N.J. Vyas, Sr Dr सुनवाई की तारीख/Date Of Hearing : 14/05/2024 घोषणा की तारीख /Date Of Pronouncement : 27/05/2024 आदेश/O R D E R Per Makarand V. Mahadeokar: Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016-17 Arises Out Of The Order Of Learned Commissioner Of Income Tax (Appeals)-4, Bengaluru (Hereinafter Referred To As 'Cit(A)’) Dated 29.02.2024, In The Matter Of Intimation Issued U/S 143(1) Issued By Cpc, Bangalore On 01.03.2019. 2. Following Are The Grounds Of Appeal Before Us:_ “1. The Ld. Cit(A) Has Erred In Upholding The Disallowance Made In The Intimation Order Passed U/S 143(1) Of The It Act Which Was Passed Without Giving Any Opportunity Of Being Heard To Your Appellant. In The Said Intimation Order, The Claim Of Exemption U/S 11 Of The It Act Is Denied & A Demand Is Raised. Such Arbitrary Disallowance Of Exemption Is Prayed To Be Deleted. 2. The Ld. Cit(A) Has Upheld The Disallowance Of Exemption U/S 11 Of The It Act In The Intimation Order Passed U/S 143(1) Of The It Act Making An Addition Of Rs. 40,67,000/- On Account Of Income Chargeable U/S 12(2) Of The Mahavir Kelavani Mandal Vs. Dcit Asst. Year : 2016-17 2

charitable trust. 12. Prior to amendment made by the Finance Act, 2016, Section 139(4) provided that a person who has not furnished

SHREE BHAKT SAMAJ VIKAS EDUCATION TRUST,BODELI vs. ASST. COMMISSIONER OF INCOME TAX EXEMPTION, VADODARA

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

charitable trust. 2. Ld. CIT Appeal also erred in not considering ITAT Ahmedabad bench order submitted with appeal. Being the case of Shri Mahudi Madhupuri Jain NSM Bhojanshalal & Prashafi Bhavan V. CPC, Bangalore Present Jurisdiction – ITO Ward-2, Exemption, Ahmedabad ITA No. 184/Ahd/2024 (Ahd-Trib.) reported in 2024 ITL 2053 order dated 04-06-2024. Shree Bhakt Samaj Vikas Education