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

57,376 100.00% ITA Nos.265, 805, 806 & 2344/Ahd/2018 DCIT vs. VyaktiVikas Kendra India Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15 8.8 It further appears that various courses conducted by the appellant trust specially part-1 and part-2 and the Apex course have a direct nexus and/or co- relation with the objects of the trust before

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

57,376 100.00% ITA Nos.265, 805, 806 & 2344/Ahd/2018 DCIT vs. VyaktiVikas Kendra India Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15 8.8 It further appears that various courses conducted by the appellant trust specially part-1 and part-2 and the Apex course have a direct nexus and/or co- relation with the objects of the trust before

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

57,376 100.00% ITA Nos.265, 805, 806 & 2344/Ahd/2018 DCIT vs. VyaktiVikas Kendra India Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15 8.8 It further appears that various courses conducted by the appellant trust specially part-1 and part-2 and the Apex course have a direct nexus and/or co- relation with the objects of the trust before

THE DCIT (EXEMPTIONS) CIRCLE-2, AHMEDABAD vs. SHREE KHODAL DHAM TRUST, KAGWAD, RAJKOT

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

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedअपील सं./Ita No.904/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2014-2015 D.C.I.T.(Exemptions) Shree Khodal Dham Trust, Circle-2, Vs. Kagwad, Ahmedabad. Alka Society, 4Th Floor, Shri Sardar Patel Bhavan, Near Water Tank, Rajkot-360004. Pan: Aajts1017J

charitable in nature. Further, SLP filed bij the Department against the above decision is also dismissed by Hon'ble Supreme Court vide order dated 1 0"' May, 2011 referred supra. 6.8 From the above it is clear that the AO cannot deny the benefits of section 11 to the Appellant trust, when, the registration u/s. 12A granted by the Commissioner

M/S. GUJARAT CRICKET ASSOCIATION,,AHMEDABAD vs. THE DY. CIT, EXEMPTIONS, CIRCLE-1,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Amarjit Singh&Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 2589/Ahd/2017 ("नधा"रण वष" / Assessment Year : 2014-15) M/S. Gujarat Cricket Dcit, बनाम/ Exemptions, Circle-1, Association Vs. Ahmedabad Iind Floor, Akshar Arcade, Opp. Memnagar Fire Station, Nr. Vijay Char Rasta, Ahmedabad- 380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaa Ag1 205 C .. (अपीलाथ"/Appellant) (""यथ" / Respondent)

charitable purpose, the contribution from BCCI is not income under Income Tax Act. III. Set off of Brought Forward Deficit: The past losses and unabsorbed depreciation is available for set off. Your Honour is requested to give the set off the same.” 6. The AO has not accepted the submission of the assessee. The AO was of the view that

THE ACIT(E), CIRCLE-1, AHMEDABAD vs. UTTHAN SEVA SANSTHAN, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: S/Shri Pramod M. Jagtap & T.R. Senthil Kumarassessment Year :2015-16

57,376, as it contends, or twenty- five per cent of Rs. 87,010, as the revenue appeared to contend. Section 11(1) (a) reads thus : "11 Income from property held for charitable or religious purposes.-(1)(a ) Income derived from property held under trust

THE DDIT (EXEMP.), AHMEDABAD vs. ADARSH FOUNDATION, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri O. P Meena & Ms. Madhumita Royआ.अ.सं/.I.T.A No.1858/Ahd/2013 िनधा"रणवष"/Assessment Year:2009-10 बनाम Deputy Director Of Income Tax Adarsh Foundation, Vs. (Exemption), Ahmedabad C/O Sal Hospital & Medical Institution, Opp. Doordarshan Tower, Drive- In-Road, Thaltej, Ahmedabad Pan:Aaa Ta2 111 J अपीलाथ" Appellant ""यथ"/Respondent

57,980/- was shown as Loans and advances in the books of the Company which was due to trust as on 31st March,2009. In my opinion, I find the contention of AO unsustainable as alongwith the movable assets entire liabilities of the trust is also transferred to the Company. The basic fact of entering in to agreement with

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

The appeal of the Revenue is dismissed

charitable purposes and, b) Accumulated /set aside for such application upto limit specified. 7.3 Before us the issue relates to the second limb of the exemption ,the limited point being whether the specified limit for setting aside/accumulation applies to gross receipts/net surplus.In short it is the question of interpretation of the term “income” used in the section ,specified percentage

THE ITO, (EXEMPTIONS), WARD-2,, AHMEDABAD vs. UTTHAN SEVA SANSTHAN,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Justice Shri P. P. Bhatt & Shri Pradip Kumar Kediaआयकर अपील सं./I.T.A. No. 2017/Ahd/2016 ("नधा"रण वष" / Assessment Year : 2012-13)

57,376, as it contends, or twenty- five per cent of Rs. 87,010, as the revenue appeared to contend. Section 11(1) (a) reads thus : "11 Income from property held for charitable or religious purposes.-(1)(a ) Income derived from property held under trust

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

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

sections 13(1)(c)(ii), 13(2)(b), 13(2)(d) and 13(2)(g) of the Act have been violated by the assessee trust. Therefore the income of the Trust is treated as Association of Person “AOP” and only expenditure incurred was allowed and thereby assessed the total income as Rs. 4,54,85,017/-. 4. Aggrieved against this

GUJARAT STATE PLASTIC MANUFACTURERS ASSOCIATION,,AHMEDABAD vs. THE DDIT(E),, AHMEDABAD

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

Bench: Shri Mahavir Prasad & Shri Amarjit Singh)

Section 2(15)— Held, it could be seen from bye-laws of Assessee that, dominant and prime objective of Assessee was not profit making—Prior to introduction of the proviso to S 2(15), there was no dispute that, Assessee was established for charitable purposes—Contribution Assessee received from non-members in conducting trade fair was Rs.15,64,556— Total

ACIT, EXEMPTIONS, CIRCLE-1, AHMEDABAD, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

57,376 100.00% 8.8 It further appears that various courses conducted by the appellant trust specially part-1 and part-2 and the Apex course have a direct nexus and/or co- relation with the objects of the trust before us. It is also relevant to mention that such contributions have been treated in the books of accounts of the trust

ITO (EXEMPTIONS), WARD-1,, AHMEDABAD vs. GUJARAT STATE PLASTIC MANUFACTURER'S ASSOCIATION,, AHMEDABAD

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

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad)

Section 2(15)— Held, it could be seen from bye-laws of Assessee that, dominant and prime objective of Assessee was not profit making—Prior to introduction of the proviso to S 2(15), there was no dispute that, Assessee was established for charitable purposes—Contribution Assessee received from non-members in conducting trade fair was Rs.15,64,556— Total

BARODA CRICKET ASSOCIATION,,BARODA vs. THE DY.CIT, CIRCLE-5., BARODA

In the result, ITA No. 2841/Ahd/17, i

section 11. He submits that the proviso to Section 2(15) will not come into play ITA Nos: 1257/Ahd/13, 3303/Ahd/16, 3304/Ahd/16, 408/Ahd/17 (Assessment years: 2009-10, 2010-11, 2011-12 and 2012-13) ITA Nos: 336 and 337/Ahd/2015 and 2957/Ahd/2014, (Assessment years: 2009-10, 2011-12, 2010-11) ITA Nos: 2839, 2840 and 2841/ Ahd/ 2017 (Assessment years

SAURASHTRA CRICKET ASSOCIATION,,RAJKOT vs. THE DY. CIT (EXEMPTION), CIRCLE-2,, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

section 11. He submits that the proviso to Section 2(15) will not come into play ITA Nos: 1257/Ahd/13, 3303/Ahd/16, 3304/Ahd/16, 408/Ahd/17 (Assessment years: 2009-10, 2010-11, 2011-12 and 2012-13) ITA Nos: 336 and 337/Ahd/2015 and 2957/Ahd/2014, (Assessment years: 2009-10, 2011-12, 2010-11) ITA Nos: 2839, 2840 and 2841/ Ahd/ 2017 (Assessment years

M/S. GUJARAT CRICKET ASSOCIATION,,AHMEDABAD vs. THE JT.. DIRECTOR OF INCOME TAX (EXEMPTION),, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

section 11. He submits that the proviso to Section 2(15) will not come into play ITA Nos: 1257/Ahd/13, 3303/Ahd/16, 3304/Ahd/16, 408/Ahd/17 (Assessment years: 2009-10, 2010-11, 2011-12 and 2012-13) ITA Nos: 336 and 337/Ahd/2015 and 2957/Ahd/2014, (Assessment years: 2009-10, 2011-12, 2010-11) ITA Nos: 2839, 2840 and 2841/ Ahd/ 2017 (Assessment years

M/S. GUJARAT CRICKET ASSOCIATION,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX EXEPTIONS, CIRCLE-1,, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

section 11. He submits that the proviso to Section 2(15) will not come into play ITA Nos: 1257/Ahd/13, 3303/Ahd/16, 3304/Ahd/16, 408/Ahd/17 (Assessment years: 2009-10, 2010-11, 2011-12 and 2012-13) ITA Nos: 336 and 337/Ahd/2015 and 2957/Ahd/2014, (Assessment years: 2009-10, 2011-12, 2010-11) ITA Nos: 2839, 2840 and 2841/ Ahd/ 2017 (Assessment years

GUJARAT CRICKET ASSOCIATION,AHMEDABAD vs. THE JT..DIRECTOR OF INCOME TAX(EXEMPTION),, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

section 11. He submits that the proviso to Section 2(15) will not come into play ITA Nos: 1257/Ahd/13, 3303/Ahd/16, 3304/Ahd/16, 408/Ahd/17 (Assessment years: 2009-10, 2010-11, 2011-12 and 2012-13) ITA Nos: 336 and 337/Ahd/2015 and 2957/Ahd/2014, (Assessment years: 2009-10, 2011-12, 2010-11) ITA Nos: 2839, 2840 and 2841/ Ahd/ 2017 (Assessment years