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20 results for “charitable trust”+ Section 270A(6)(a)clear

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Key Topics

Section 12A26Section 14A16Section 270A15Section 8012Exemption12Penalty12Section 271(1)(c)10Section 143(3)10Addition to Income10

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

In the result, appeal of the assessee is partly allowed

ITA 769/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad07 Jan 2025AY 2015-16

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

Section 11Section 12ASection 143(3)Section 147Section 68

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

GUJARAT ENERGY DEVELOPMENT AGENCY,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

Disallowance10
Section 2638
Deduction8

In the result, the appeal of the assessee in ITA No

ITA 1180/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

6 of 13 under Section 11 of the Act in respect of voluntary contribution in the form of “Grants from Government” and “Other donations”, which were applied for charitable purpose. It is found that the assessee had disclosed total voluntary contribution of Rs.1,17,18,89,144/- during the year which was applied towards charitable purpose and no taxable income

GUJARAT ENERGY DEVELOPMENT AGENCY,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeal of the assessee in ITA No

ITA 1179/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

6 of 13 under Section 11 of the Act in respect of voluntary contribution in the form of “Grants from Government” and “Other donations”, which were applied for charitable purpose. It is found that the assessee had disclosed total voluntary contribution of Rs.1,17,18,89,144/- during the year which was applied towards charitable purpose and no taxable income

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

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

ITA 795/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Urvashi Sodhan, A.RFor Respondent: Shri Ramesh Kumar, Sr. D.R
Section 11Section 12ASection 2(15)Section 234BSection 25Section 251(2)Section 270ASection 8

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

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

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

ITA 1559/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2018-19

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

For Appellant: Shri M K Patel, AdvocateFor Respondent: Smt. Mamta Singh, Sr. DR
Section 11(1)(a)Section 12ASection 143(3)Section 250

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

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

ITA 849/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

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

ITA 847/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

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

ITA 913/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

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

ITA 915/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

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

ITA 850/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate order

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

ITA 912/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

270A for misreporting/underreporting were also initiated. 3. In appeal before CIT(Appeals), the assessee raised grounds challenging the 14A disallowance, the allocation of employee benefit expenses, the disallowances under section 37(1), the PF disallowance, the rejection of additional claims regarding MAT computation, and the computation of 80-IE deduction and MAT credit. 4. In the appellate 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

ITA 1917/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kambleassessment Year 2019-20

For Appellant: Shri Sunil Piyush Shah, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 132Section 132(4)Section 144BSection 147Section 148ASection 244ASection 250Section 270ASection 270A(9)Section 29A

6. That the initiation of penalty proceedings under section 270A and rejection of immunity under section 270AA are wholly unsustainable in law, since the reassessment order contains no finding invoking section 270A(9) or identifying circumstances of misreporting. The penalty notice is templated and conclusory, and cannot form the basis for denying immunity. 7. That the voluntary payments 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

ITA 2614/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

6– of appeal. The CIT(Appeals) rejected the plea of bona fide belief regarding exemption under section 10(23C) of the Act on the ground that no documentary evidence or quantitative details, such as total receipts and extent of Government funding, were furnished either before the Assessing Officer or during appellate proceedings. The CIT(Appeals) further noted that section

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

ITA 2613/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

6– of appeal. The CIT(Appeals) rejected the plea of bona fide belief regarding exemption under section 10(23C) of the Act on the ground that no documentary evidence or quantitative details, such as total receipts and extent of Government funding, were furnished either before the Assessing Officer or during appellate proceedings. The CIT(Appeals) further noted that section

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

ITA 2612/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

6– of appeal. The CIT(Appeals) rejected the plea of bona fide belief regarding exemption under section 10(23C) of the Act on the ground that no documentary evidence or quantitative details, such as total receipts and extent of Government funding, were furnished either before the Assessing Officer or during appellate proceedings. The CIT(Appeals) further noted that section

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

ITA 2615/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

6– of appeal. The CIT(Appeals) rejected the plea of bona fide belief regarding exemption under section 10(23C) of the Act on the ground that no documentary evidence or quantitative details, such as total receipts and extent of Government funding, were furnished either before the Assessing Officer or during appellate proceedings. The CIT(Appeals) further noted that section

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

ITA 2616/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

6– of appeal. The CIT(Appeals) rejected the plea of bona fide belief regarding exemption under section 10(23C) of the Act on the ground that no documentary evidence or quantitative details, such as total receipts and extent of Government funding, were furnished either before the Assessing Officer or during appellate proceedings. The CIT(Appeals) further noted that section

MUNJAL AUTO INDUSTRIES LIMITED,VADODARA, GUJARAT vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2(1)(1), VADODARA, VADODARA, GUJARAT

In the result, the appeal of the assessee is allowed for statistical purposes with the direction that the matter is restored to the file of the CIT(A) for adjudication afresh in accordance with law

ITA 271/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Sept 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2018-19 Munjal Auto Industries Ltd. Dcit, Cir.2(1)(1) 187 Gide Estate Vadodara. Waghodia Dist. Vadodara-391 760 Gujarat. Pan: Aaacg 8588 L (Applicant) (Responent) : Ms.Amrin Pathan, Ar Assessee By : Shri Yoeesh Mishra, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 15/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 17/09/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Yoeesh Mishra, Sr.DR
Section 115JSection 143(3)Section 14ASection 234CSection 250Section 251Section 270ASection 80G

section 14A read with rule 8D of the Income Tax Rules, 1962 (“the Rules”) and thereby making disallowance of Rs. 53,36,814. 5. The learned CIT(A) erred in fact and in law in confirming the action of the learned AO and making disallowance u/s 14A of the Act without appreciating the facts on record in proper perspective. 6

ITO (EXEMPTIONS) WARD-2 AHMEDABAD, AHMEDABAD vs. SHREE ASANDAS B MURJANI EDUCATION TRUST, AHMEDABAD

In the result, both the appeals of the Revenue are dismissed

ITA 1223/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2019-20

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 1223 & 1224/Ahd/2025 Assessment Year 2019-20

For Appellant: Shri Jaimin Shah, A.RFor Respondent: Shri R.P. Rastogi, CIT-D.R
Section 11(1)(c)Section 12ASection 142(1)Section 143(2)Section 270A

charitable or religious purposes or of the stated objects of the trust/institution to the tune of Rs. 2,45,00,281/- and claimed exemption u/s. 11(1)(c) of the Income Tax Act, 1961. Since the assessee was not a valid trust for assessment year 2019-20 due to non-possession of certificate u/s. 12AA of the Act, therefore claim

ITO(E) WARD-2 AHMEDABAD, AHMEDABAD vs. SHREE ASANDAS B MURJANI EDUCATION TRUST, AHMEDABAD

In the result, both the appeals of the Revenue are dismissed

ITA 1224/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2019-20

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 1223 & 1224/Ahd/2025 Assessment Year 2019-20

For Appellant: Shri Jaimin Shah, A.RFor Respondent: Shri R.P. Rastogi, CIT-D.R
Section 11(1)(c)Section 12ASection 142(1)Section 143(2)Section 270A

charitable or religious purposes or of the stated objects of the trust/institution to the tune of Rs. 2,45,00,281/- and claimed exemption u/s. 11(1)(c) of the Income Tax Act, 1961. Since the assessee was not a valid trust for assessment year 2019-20 due to non-possession of certificate u/s. 12AA of the Act, therefore claim