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

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

BHOJALRAM LEUVA PATEL SEVA SAMAJ TRUST,DEVKI GALOL vs. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), AHMEDABAD, AHMEDABAD

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

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

Section 12AA. In the case of Dawoodi Bohara Jamat 43 taxmann.com 243 (SC), the Hon'ble Supreme Court made the following observations: ITA Nos. 667&668/Ahd/2023 Bhojalram Leuva Patel Seva Samaj Trust vs. CIT(E) Asst. Year –2023-24 “40. Further, establishment of Madarsa or institutions to impart religious education to the masses would qualify as a charitable

BHOJALRAM LEUVA PATEL SEVA SAMAJ TRUST,DEVKI GALOL vs. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), AHMEDABAD, AHMEDABAD

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

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

Section 12AA. In the case of Dawoodi Bohara Jamat 43 taxmann.com 243 (SC), the Hon'ble Supreme Court made the following observations: ITA Nos. 667&668/Ahd/2023 Bhojalram Leuva Patel Seva Samaj Trust vs. CIT(E) Asst. Year –2023-24 “40. Further, establishment of Madarsa or institutions to impart religious education to the masses would qualify as a charitable

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 trust in existence since 2001 and registered under Section 12AA of the Act. The assessee had received 80,00,000 numbers of equity shares of e-Infochips Limited as corpus donation from its trustee Shri Pratul Krishnakant Shroff on 12.12.2017. Thereafter, all the shares of e-Infochips Limited, including those held by the assessee, were acquired by Arrow Electronics

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

40 Taxman 388/172 ITR 698 (Guj), the High Court held that when a donor-trust which is itself a charitable and religious trust donates its income to another trust, provisions of 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

charitable trust in existence since\n2001 and registered under Section 12AA of the Act. The assessee\nhad received 80,00,000 numbers of equity shares of e-Infochips\nLimited as corpus donation from its trustee Shri Pratul Krishnakant\nShroff on 12.12.2017. Thereafter, all the shares of e-Infochips\nLimited, including those held by the assessee, were acquired by\nArrow Electronics

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

charitable trust in existence since\n2001 and registered under Section 12AA of the Act. The assessee\nhad received 80,00,000 numbers of equity shares of e-Infochips\nLimited as corpus donation from its trustee Shri Pratul Krishnakant\nShroff on 12.12.2017. Thereafter, all the shares of e-Infochips\nLimited, including those held by the assessee, were acquired by\nArrow Electronics

NATIONAL REAL ESTATE DEVELOPMENT COUNCIL GUJARAT,AHMEDABAD vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokarassessment Year : - National Real Estate Development Vs. Commissioner Of Council Gujarat Income-Tax (Exemption) B-807, Times Square-2 Ahmedabad. Nr.Avlon Hotel, Thaltej Ahmedabad. Pan : Aagan 1280 J

trust were primarily charitable rather than favouring any specific religious community, CIT(E) was not justified in denying registration under Section 12A, by invoking Section 13(1)(b) as said provisions would be attracted only at time of assessment and not at time of grant of registration. In the case of Malik Hasmullah Islamic Educational and Welfare Society

ROTARY INTERNATIONAL DISTRICT 3054 CHARITABLE TRUST ,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 12AB(4) of the Act. Thus CIT(E) denied the registration u/s. 12AB of the Act and also cancelled the provisional registration granted to the assessee trust. 3. Aggrieved against the same, the assessee is in appeal before us raising the following Grounds of Appeal: 1. On facts and circumstances of the case and in law, the order passed

OM SEVA DHAM,BHAVNAGAR vs. CIT(EXEMPTION), AHMEDABAD

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

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kambleom Seva Dham, The Commissioner Of Income Vs. 37 Swapnasrushti Township, Tax (Exemption), Talaja Road, Ahmedabad. Opp Top 3 Cinema, Bhavnagar-364002. [Pan : Aaato4182 F] (Appellant) .. (Respondent) Appellant By : Shri Vivek Chavda, Ar Respondent By: Shri R P Rastogi, Cit. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 23.02.2026

40 individuals from diverse backgrounds (b) Not examining whether any actual religious expenditure exceeded the 5% limit under Section 80G(5B) (c) Not appreciating the distinction between spiritual activities and religious activities 2.1 The learned CIT(Exemption) erred in treating the trust as a composite trust (religious-cum-charitable

AMBICA EDUCATION TRUST,HIMATNAGAR vs. THE ADIT, CPC PRESENT JURIS. THE ITO, EXEMPTION, PALANPUR

In the result, the appeals filed by the Assessee are allowed for statistical purposes

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

trust is registered under section 12AA of the Act for the past 40 years and the said registration is still in existence. It is also not the case of the Revenue that the assessee has ceased to be a religious or charitable

AMBICA EDUCATION TRUST,HIMATNAGAR vs. THE ADIT, CPC PRESENT JURIS. THE ITO, EXEMPTION, PALANPUR

In the result, the appeals filed by the Assessee are allowed for statistical purposes

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

trust is registered under section 12AA of the Act for the past 40 years and the said registration is still in existence. It is also not the case of the Revenue that the assessee has ceased to be a religious or charitable

DCIT CIRCLE 1 (E) AHMEDABAD, AHMEDABAD vs. ADARSH FOUNDATION, AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

40% of SCPL's profit, whichever was higher, as management fees. The assessee Trust had incurred heavy debts, including both secured and unsecured loans, and faced a negative net worth as of 2007-08. The agreement was seen as a means to ensure the assessee Trust's survival and continued charitable activities, as SCPL took over the hospital's operations

CHIMANLAL MODI CHARITABLE TRUST,MEHSANA vs. CIT (EXEMPTION), AHMEDABAD, AHMEDABAD

In the result, the appeal filed by the assessee in ITA No

Bench: Six Months From The Date Of Commencement Of The Activities, Which Was Further Extended By Cbdt Circular No. 7 Of 2024 Up To 30-06- 2024 But The Assessee Trust Had Not Filed Any Reason For Delay In Filing Such Application. Therefore Ld. Cit(E) Denied The Registration By Observing That The Application Is Filed Belatedly.

Charitable CIT (Exemption), Trust Ahmedabad 40, Shrinathji Residency, Vs Patan Road, Mehsana Gujarat-384170 PAN: AADTC0026F (Respondent) (Appellant) Assessee Represented: None Revenue Represented: Shri Rignesh Das, CIT-DR Date of hearing : 05-03-2026 Date of pronouncement : 10-03-2026 आदेश/ORDER PER: T.R. SENTHIL KUMAR, JUDICIAL MEMBER These two appeal are filed by the Assessee as against separate orders

CHIMANLAL MODI CHARITABLE TRUST,MEHSANA vs. CIT (EXEMPTION), AHMEDABAD, AHMEDABAD

In the result, the appeal filed by the assessee in ITA No

Bench: Six Months From The Date Of Commencement Of The Activities, Which Was Further Extended By Cbdt Circular No. 7 Of 2024 Up To 30-06- 2024 But The Assessee Trust Had Not Filed Any Reason For Delay In Filing Such Application. Therefore Ld. Cit(E) Denied The Registration By Observing That The Application Is Filed Belatedly.

Charitable CIT (Exemption), Trust Ahmedabad 40, Shrinathji Residency, Vs Patan Road, Mehsana Gujarat-384170 PAN: AADTC0026F (Respondent) (Appellant) Assessee Represented: None Revenue Represented: Shri Rignesh Das, CIT-DR Date of hearing : 05-03-2026 Date of pronouncement : 10-03-2026 आदेश/ORDER PER: T.R. SENTHIL KUMAR, JUDICIAL MEMBER These two appeal are filed by the Assessee as against separate orders