DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

charitable purposes, the income generated from such activities shall not be treated as income derived from property held under the trust within the meaning of section 11(1)(a) of the Act. 7.8. The assessment was ultimately finalized by and under an order dated 28.03.2014 holding that the activities of the assessee does not fall under clause “Education and medical

THE ACIT, (EXEMPTION) CIRCLE-1, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

charitable purposes, the income generated from such activities shall not be treated as income derived from property held under the trust within the meaning of section 11(1)(a) of the Act. 7.8. The assessment was ultimately finalized by and under an order dated 28.03.2014 holding that the activities of the assessee does not fall under clause “Education and medical

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

charitable purposes, the income generated from such activities shall not be treated as income derived from property held under the trust within the meaning of section 11(1)(a) of the Act. 7.8. The assessment was ultimately finalized by and under an order dated 28.03.2014 holding that the activities of the assessee does not fall under clause “Education and medical

CHAMUNDA FOUNDATION,AHMEDABAD vs. THE CIT,, GANDHINAGAR

In the result, the CO No.83/Ahd/2015 filed by the assessee is allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl.

charitable in nature, he has the power to cancel it. 2) The AO has to apply the provisions of section 11, 12, & 13 of the Act, though the assessee is registered u/s 12AA of the Act. 3) The huge profit generated by the trust establishes the fact that the motive of the trust is to earn profit

ITO(EXEMPTIONS),, AHMEDABAD vs. CHAMUNDA FOUNDATION,, AHMEDABAD

In the result, the CO No.83/Ahd/2015 filed by the assessee is allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl.

charitable in nature, he has the power to cancel it. 2) The AO has to apply the provisions of section 11, 12, & 13 of the Act, though the assessee is registered u/s 12AA of the Act. 3) The huge profit generated by the trust establishes the fact that the motive of the trust is to earn profit

DCIT, CENTRAL CIRCLE1(2), AHMEDABAD, AHMEDABAD vs. PARUL AROGYA SEVA MANDAL TRUST, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

charitable basis. ITA No 991,992,993,1018 & 1019/Ahd/2023. Parul Arogya Seva Mandal Trust & Parul University (ITA 993/Ahd/2023) Asst. Years :2016-17 & 2017-18 3 Parul Arogya Seva Mandal Trust (PAN: AAATP4313K), the assessee is registered u/s. 12AA of the Act, vide No. HQ-3/32/P-4/96-97/Range-4 dated 07.08.1996. The assessee Trust is also registered

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD, AAYAKAR BHAWAN, ASHRAM ROAD, AHMEDABAD vs. PARUL AROGYA SEVA MANDAL TRUST, , AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

charitable basis. ITA No 991,992,993,1018 & 1019/Ahd/2023. Parul Arogya Seva Mandal Trust & Parul University (ITA 993/Ahd/2023) Asst. Years :2016-17 & 2017-18 3 Parul Arogya Seva Mandal Trust (PAN: AAATP4313K), the assessee is registered u/s. 12AA of the Act, vide No. HQ-3/32/P-4/96-97/Range-4 dated 07.08.1996. The assessee Trust is also registered

PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

charitable basis. ITA No 991,992,993,1018 & 1019/Ahd/2023. Parul Arogya Seva Mandal Trust & Parul University (ITA 993/Ahd/2023) Asst. Years :2016-17 & 2017-18 3 Parul Arogya Seva Mandal Trust (PAN: AAATP4313K), the assessee is registered u/s. 12AA of the Act, vide No. HQ-3/32/P-4/96-97/Range-4 dated 07.08.1996. The assessee Trust is also registered

PARUL UNIVERSITY,VADODARA vs. THE DY.CIT,EXEMPTION CIRCLE-1, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

charitable basis. ITA No 991,992,993,1018 & 1019/Ahd/2023. Parul Arogya Seva Mandal Trust & Parul University (ITA 993/Ahd/2023) Asst. Years :2016-17 & 2017-18 3 Parul Arogya Seva Mandal Trust (PAN: AAATP4313K), the assessee is registered u/s. 12AA of the Act, vide No. HQ-3/32/P-4/96-97/Range-4 dated 07.08.1996. The assessee Trust is also registered

PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

charitable basis. ITA No 991,992,993,1018 & 1019/Ahd/2023. Parul Arogya Seva Mandal Trust & Parul University (ITA 993/Ahd/2023) Asst. Years :2016-17 & 2017-18 3 Parul Arogya Seva Mandal Trust (PAN: AAATP4313K), the assessee is registered u/s. 12AA of the Act, vide No. HQ-3/32/P-4/96-97/Range-4 dated 07.08.1996. The assessee Trust is also registered

DAWOODI BOHRA MUSAFIRKHANA TRUST,KHAMBHAT vs. THE ITO, WARD (EXEMPTION), VADODARA

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

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyalिनधा"रण वष"/Assessment Year: 2016-17 Vs. Dawoodi Bohra Musafirkhana Income-Tax Officer, Trust, Ward (Exemption), 1, Dawoodi Bohra Musafirkhana, Vadodara Opp. Bus Stand, Khambhat, Gujarat-388620 Pan : Aaatd 2007 L अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Ankit Chokshi, Ar Revenue By : Shri Ashok Kumar Suthar, Sr Dr सुनवाई क" क" तारीख तारीख/Date Of Hearing : 08.02.2024 सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 03.05.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta:

charitable or religious purposes and the provisions of that section and section 13 shall apply accordingly.” 19. Corpus donations, therefore, being identified and recognized in law as distinct and separate from Incomes derived from property held under Trust and both being granted exemption separately u/s 11(1)(a) and 11(1)(d) of the Act, there arises no question

SHRI RAJESH RAVINDRAN CHARITY TRUST,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, appeal filed by the assessee is allowed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

Section 80G(5) of the Act reads as under: “(iii) the institution or fund is not expressed to be for the benefit of any particular religious community or caste;” The said sub-clause states that a fund institution established for charitable purposes should not be expressed to be for the benefit of any particular religious community or caste

GIVE FOUNDATION,BANGALORE vs. THE DY.CIT, CIRCLE-1(EXEMPTION), AHMEDABAD

In the result, the primary matter involved in all the Assessment

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

charitable in nature and covered under main limbs of section 2(15) of the Act. Tax Effect: NIL, being technical ground. 6.(a) Ld. NFAC erred in law and on facts in ignoring submission that aggregate receipts of charity fees or Give India Listing Income does not exceed 20% of the total receipts and accordingly proviso to section

SANDEEP MOHANRAJ SINGHI,AHMEDABAD vs. ACIT, CIRCLE4(2), AHMEDABAD, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

charitable or religious institution, if any part of such income or any property of the trust or the institution is, during the previous year, used or ITA Nos.1205 & 769/Ahd/2025 Assessment Years: 2018-19 ACIT(E) vs. Dr. KR Shroff Foundation Page 22 of 24 applied directly or indirectly for the benefit of any person referred to in sub- section

DR K R SHROFF FOUNDATION,AHMEDABAD vs. THE DY. CIT, CIRCLE-1, EXMP, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

22 of 24\napplied directly or indirectly for the benefit of any person referred to in sub-\nsection (3). Sub-section (3) of section 13, in turn, specifies the persons referred\nto in clause (c) of sub-section (1) which includes the author of the trust or the\nfounder of the institution, any trustee of the trust or manager

ACIT (EXEMPTION) CIRCLE 1 AHMEDABAD, AHMEDABAD vs. DR K R SHROFF FOUNDATION, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

section 11 shall operate so as to exclude\nfrom the total income of the assessee being a trust for charitable or religious\npurpose or a charitable or religious institution, if any part of such income or any\nproperty of the trust or the institution is, during the previous year, used or\n\nITA Nos.1205 & 769/Ahd/2025\n Assessment Years

VISMRUTI SOCIAL AND CHARITABLE TRUST,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, appeal of the assessee / applicant trust is allowed for\nstatistical purposes

22 objects, of which only two objects were considered\nreligious in nature. The counsel for the assessee submitted that the trust is\nprimarily engaged in charitable activities such as education, medical relief,\naid for the poor, and environmental preservation. It was submitted that\nsection 80G(5B) of the Act allows trusts which incur religious expenditures\nnot exceeding 5% of their

THE DY. COMMR. OF INCOME TAX, (EXEMPTION) CIRCLE-2,, AHMEDABAD vs. JAMNAGAR AREA DEVELOPMENT AUTHORITY, JAMNAGAR

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

Bench: Shri Pradip Kumar Kedia & Smt. Madhumita Roy

22 - donation and are eligible for deduction u/s,11(1)(d). Thus, such specific project grants cannot be considered as income derived from the property held under the trust u/s.11(1)(a). Such projects specific grants cannot be used by the trust/institution freely towards the objects of the trust Such trusts/institutions have to act as a trustee of a special