AIA ENGINEERING 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)

144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2017-18 and 2018-19. Since the solitary issue in both the asst. years is Whether CSR expenditure is allowable under section 80G of the Act, hence the above appeals are disposed of by this common order for the sake of convenience

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)

144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2017-18 and 2018-19. Since the solitary issue in both the asst. years is Whether CSR expenditure is allowable under section 80G of the Act, hence the above appeals are disposed of by this common order for the sake of convenience

DAWOODI BOHRA JAMAT GODHRA,GODHRA vs. THE INCOME TAX OFFICER, WARD-EXEMPTION, VADODARA

In the result, the appeal of the assessee is allowed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1567/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Dawoodi Bohra Jamat Godhra The Income Tax Officer बनाम/ Dawoodi Bohra Masjid Ward Exemption V/S. Vohrawad, Godhra Vadodara Godhra – 389 001 (Gujarat) "थायी लेखा सं./Pan: Aaatd 4476 D (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Ms. Urvashi Sodhan, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05/12/2024 घोषणा की तारीख /Date Of Pronouncement: 09/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

Section 271AAC of the Act. 4. Aggrieved by the order of the CIT(A), the assessee is in appeal before us with following grounds of appeal: 1. The Ld. CIT (A) has erred in law and on facts of appellant's case in holding that the assessment order passed U/s 147 r.w.s. 144 r.w.s. 144B of the Act is Valid

BHAVNATH EDUCATION TRUST,BAVNAGAR vs. THE ITO(EXEMPTION) WARD, BHAVNAGAR

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

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1559/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2018-19) बनाम/ Bhavnath Education Trust Income Tax Officer Bhanagar Highway, Dist. (Exemption) Vs. Bhavnagar, Ranghola- Ward, Bhavnagar 364230 / Aayakar Bhawan, Income Sanghavi & Company, Tax Office, Bhavanagar Prasham, 4Th Floor, Kasturba Road, Nr. Bilkha Plaza, Rajkot - 360001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaatb2003J (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri M K Patel, Advocate ""यथ" क" ओर से/Respondent By : Smt. Mamta Singh, Sr. Dr Date Of Hearing 06/01/2026 07/01/2026 Date Of Pronouncement

Charitable or religious purpose or set apart for specified purpose. The assessee Trust does not offered the surplus amount for taxation during the year under consideration. Hence the amount of Rs.40,03,428/- is disallowed and added to the total income of the assessee. ITA No.1559/Ahd/2025 [Bhavnath Education Trust vs. ITO(E)] A.Y. 2018-19 - 6 – Assessment order

SUNIL PIYUSH SHAH,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. -THE ITO, WARD-5(3)(2), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Ms. Suchitra Kambleassessment Year 2019-20

144B and the appellate order dated 05.09.2025 passed under section 250 are vitiated in law, having been framed and upheld without furnishing the Appellant with any incriminating material specific to him, and without I.T.A No. 1917/Ahd/2025 Sunil Piyush Shah, A.Y. 2019-20 granting an opportunity to cross-examine the persons whose statements were relied upon. The orders suffer from gross

SURAT URBAN DEVELOPMENT AUTHORITY,SUDA BHAWAN, NANPURA vs. CIT(EXEMPTION), AHMEDABAD, AAYKAR BHAWAN (VEJALPUR)

In the result, the appeal of the assessee is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2018-19 Surat Urban Development The Cit(Exemption) Authority (Suda) Vs Vejalpur, Ahmedabad. Suda Bhawan Nanpura, Surat. Pan : Aaals 0197 G (Applicant) (Responent) Assessee By : Shri Rasesh Shah, Ar : Shri Prathvi Raj Meena, Cit Revenue By सुनवाई की तारीख/Date Of Hearing : 08/01/2025 घोषणा की तारीख /Date Of Pronouncement: 02/04/2025 आदेश/O R D E R

trust i.e. development and sale/ leasing of housing projects and other projects and general development, and whether or not these activities fell under the provisions of section 2(15) of the Act i.e. objects of general public utility against the charges not being a charitable purpose. The para 2.1 to 2.2 of the ld.CIT’s order recording the above

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

charitable institutions, which were distinct from the statutory CSR obligation. The AR relied on the decision of Coordinate Bench in case of Gujarat State Financial Services Ltd. v. DCIT [2025] 174 taxmann.com 461 (ITAT Ahmedabad), where it was held that section 80G(2)(a)(iiihk)/(iiihl) bars deduction only for donations to Swachh Bharat Kosh and Clean Ganga Fund

SHRI JALARAM AROGYA SEVA TRUST,SABARKANTHA vs. THE ITO (EXEMPTION), PALANPUR

The appeal of the assessee is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2019-20

Charitable Trust Act u/s. 12A of the Income Tax Act. The assessee filed its return of income on 24-10-2019 declaring total income at Rs. nil after claiming exemption u/s. 11 of the Act. The Assessing Officer observed that the assessee filed revised return of income on 22-02-2020 declaring total income of Rs. nil. Even

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

144B of the Act due to complete non- compliance on the part of the assessee to the statutory notices issued by the Assessing Officer. It is also evident that the learned CIT(Appeals) dismissed the appeal of the assessee in limine on account of delay of 257 days in filing the appeal and, consequently, did not adjudicate the issues arising

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

144B of the Act due to complete non- compliance on the part of the assessee to the statutory notices issued by the Assessing Officer. It is also evident that the learned CIT(Appeals) dismissed the appeal of the assessee in limine on account of delay of 257 days in filing the appeal and, consequently, did not adjudicate the issues arising

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

144B of the Act due to complete non- compliance on the part of the assessee to the statutory notices issued by the Assessing Officer. It is also evident that the learned CIT(Appeals) dismissed the appeal of the assessee in limine on account of delay of 257 days in filing the appeal and, consequently, did not adjudicate the issues arising

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

144B of the Act due to complete non- compliance on the part of the assessee to the statutory notices issued by the Assessing Officer. It is also evident that the learned CIT(Appeals) dismissed the appeal of the assessee in limine on account of delay of 257 days in filing the appeal and, consequently, did not adjudicate the issues arising

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

144B of the Act due to complete non- compliance on the part of the assessee to the statutory notices issued by the Assessing Officer. It is also evident that the learned CIT(Appeals) dismissed the appeal of the assessee in limine on account of delay of 257 days in filing the appeal and, consequently, did not adjudicate the issues arising

SHALBY LTD.,AHMEDABAD vs. THE PCIT, AHMEDABAD-3, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Years: 2020-21

charitable organisation groups in March 2021 and AISECT was also covered in the search action. It was found that this assessee was engaged in bogus donation scheme. The donations received through banking channels used to be returned back after charging a commission. Therefore, the donation of Rs. 3 crores made by the assessee to AISECT Trust was not genuine

ANAND EDUCATION TRUST,AHMEDABAD vs. THE ITO, WARD-1 (EXEMPTIONS), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

144B of the Act dated 22.03.2023,\nwherein the Assessing Officer [hereinafter referred to as “AO”] made an\naddition of Rs.1,37,90,000/- under Section 69A of the Act, taxed under Section\n115BBE of the Act.\nFacts of the Case:\n2.\nThe assessee is a 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

BHOLARAM EDUCATION SOCIETY,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP., AHMEDABAD

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

Bench: Dr. Brr Kumar & Ms. Suchitra R. Kambleassessment Year : 2018-19 Bholaram Education Society Vs. The Dcit, Cir.1 C/O. Delhi Public School (Exemption) Ambapur Village Ahmedabad. Nr.Koba Circle Koba Adalaj Link Road Gandhinagar 382 007. Pan : Aaatb 8415 E (Applicant) (Responent) Assessee By : Shri Mehl K. Patel, Advocate : Shri J.L. Bhatia, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 22/11/2024 घोषणा क" तारीख /Date Of Pronouncement: 22/11/2024 आदेश आदेश/O R D E R आदेश आदेश

charitable trust, the appeal may please be taken up out of turn or in the alternative, the demand raised may be stayed till the disposal of the appeal and no recovery proceedings be initiated till then. 4. The facts emanate from the orders of the Revenue authorities in this case are that the assessment order has been passed

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY,,AHMEDABAD vs. THE COMMISSIONER OF INCOME TAX(EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

trust, did not file its return of income for the Assessment Year (A.Y.) 2018-19. Thereafter, the Assessing Officer observed that the assessee had undertaken certain transactions, the source of which remained unexplained. The Assessing Officer issued notice u/s issued notice u/s 148 of the Act. of the Act, in response to which the assessee filed return of income declaring