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 Public Trust [2015] 56 taxmann.com 182. 5.9 As discussed above, the denial of exemption section 11 & 12 by the AO is based on the incriminating documents found during the course of survey. In this regard the appellant reiterated that they have offered sum of Rs. 18.90 crore in PMGKY and taken the benefit of the scheme which covers more

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 Public Trust [2015] 56 taxmann.com 182. 5.9 As discussed above, the denial of exemption section 11 & 12 by the AO is based on the incriminating documents found during the course of survey. In this regard the appellant reiterated that they have offered sum of Rs. 18.90 crore in PMGKY and taken the benefit of the scheme which covers more

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 Public Trust [2015] 56 taxmann.com 182. 5.9 As discussed above, the denial of exemption section 11 & 12 by the AO is based on the incriminating documents found during the course of survey. In this regard the appellant reiterated that they have offered sum of Rs. 18.90 crore in PMGKY and taken the benefit of the scheme which covers more

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

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

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

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

SHRI BHAVNAGAR DASHASHRIMALI KANTHIBANDH (VAISHNAV) VANIK GNATI,BHAVNAGAR vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal in ITA No

Bench: Ms. Suchitra R. Kamble & Shri Makarand V.Mahadeokar

charitable activity), but not in full force, because the present assessee’s registration is governed by the post-amendment section 12AB(4) regime. 4.8 Thus, while the earlier decisions protect older trusts from denial of registration merely for community-based objects, a newly created trust (like the present one) is subject to statutory oversight under section 12AB(4), which allows

SHRI BHAVNAGAR DASHASHRIMALI KANTHIBANDH (VAISHNAV) VANIK GNATI,BHAVNAGAR vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal in ITA No

charitable and religious\ntrusts was governed by sections 12A and 12AA. Under that regime the\nCommissioner's power was limited to verifying the objects and genuineness\nof activities of the trust. There was no codified provision defining “specified\nviolations" or authorising cancellation on that ground. Cancellation could\nbe invoked only under section 12AA(3) upon finding that activities were

AKSHAT EDUCATION AND CHARITABLE TRUST,ANAND vs. THE ITO, WARD- EXEMPTION, VADODARA

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

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.457/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-2021 Akshat Education & Charitable The Income Tax Officer, Trust, बनाम Ward (Exemption), / 5/35, Gosainu Faliyu, Vadodara. V/S. Asodar Borsad Road, Asodar, Anand-388307. (Gujarat) "थायी लेखा सं./Pan: Aaeta2211K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Mehul Thakkar, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 14/08/2025 घोषणा की तारीख /Date Of Pronouncement: 19/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Assessee Is Directed Against The Order Of The Learned Joint Commissioner Of Income Tax (Appeals)-2, Coimbatore [Hereinafter Referred To As “Ld. Cit(A)”] Dated 25.01.2025, Passed Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”] For The Assessment Year 2020–21. The Impugned Order Arises Out Of The Akshat Education & Charitable Trust Vs. Ito(E) Assessment Year 2020-21

trust is engaged in running a school and imparting education, which is its stated charitable object. For the year under consideration, the assessee filed its return of income in Form ITR-7 on 31.03.2021, declaring nil income after claiming exemption under section 11 of the Act on total gross receipts of Rs. 1,99,48,893/-. Along with the return

THE DY. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. MUDRA FOUNDATION FOR COMMUNICATION RESEARCH & EDUCATION,, AHMEDABAD

In the result, the appeal is dismissed

69,427/- on account of capital expenditure.” 3. The issue in appeal lies within a narrow compass of material facts. During the course of scrutiny assessment proceedings, the Assessing Officer took note of the ITA No. 2424/Ahd/2017 & CO No.11/Ahd/2019 DCIT Vs. Mudra Foundation for Comn Rsrch & Edn Assessment year: 2014-15 Page 2 of 7 assessee’s claim that

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

69. In the case of Addl. Commissioner of Income Tan v. Surat Art Silk Cloth Manufacturers Association: [1980] 121 ITR 1 (SC), the Supreme Court held as under: The test which has, therefore, now to be applied is whether the predominant object of the activity involved in carrying out the object of general public utility is to subserve the charitable

THE ITO(EXEMPTIONS), WARD-2,, AHMEDABAD vs. POLIO FOUNDATION,, AHMEDABAD

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

69 and submitted that the capital expenditure has been treated as application towards the object of the trust. Therefore there cannot be any disallowance u/s 11 of the Act. As such it has not accumulated or set a part any fund as provided under section 11(2) of the Act. 5.1 The Ld. AR drew our attention on the income

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

In the result, the appeal of the Assessing Officer for the assessment year 2007-

Bench: Us. It Is, Accordingly, Dismissed For Want Of Prosecution.

Charitable Trust derived from building, plant and machinery and furniture was liable to be computed in normal commercial manner although the Trust may not be carrying on any business and the assets in respect whereof depreciation is claimed may not be business assets. In all such cases, section 32 of the Income-tax Act providing for depreciation for computation

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

In the result, the appeal of the Assessing Officer for the assessment year 2007-

Bench: Us. It Is, Accordingly, Dismissed For Want Of Prosecution.

Charitable Trust derived from building, plant and machinery and furniture was liable to be computed in normal commercial manner although the Trust may not be carrying on any business and the assets in respect whereof depreciation is claimed may not be business assets. In all such cases, section 32 of the Income-tax Act providing for depreciation for computation

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

In the result, the appeal of the Assessing Officer for the assessment year 2007-

Bench: Us. It Is, Accordingly, Dismissed For Want Of Prosecution.

Charitable Trust derived from building, plant and machinery and furniture was liable to be computed in normal commercial manner although the Trust may not be carrying on any business and the assets in respect whereof depreciation is claimed may not be business assets. In all such cases, section 32 of the Income-tax Act providing for depreciation for computation

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

In the result, the appeal of the Assessing Officer for the assessment year 2007-

Bench: Us. It Is, Accordingly, Dismissed For Want Of Prosecution.

Charitable Trust derived from building, plant and machinery and furniture was liable to be computed in normal commercial manner although the Trust may not be carrying on any business and the assets in respect whereof depreciation is claimed may not be business assets. In all such cases, section 32 of the Income-tax Act providing for depreciation for computation