GROW FOUNDATION GANDHINAGAR,GANDHINAGAR vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is allowed for 9

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

Section 80G(5) of the Act. While passing the order, the ITAT made the following observations:- “8. In our considered view, the ITAT in the case of CIT-1982, Charitable Trust

THE NA vs. ARI AGRICULTURAL UNIVERSITY,NAVSARIVS.THE COMMISSIONER OF INCOME TAX(E), AHMEDABAD

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

Bench: 30.09.2022 As It Has Already Commenced 06.03.2004 Activities On 06-03-2022. 2. The Ld Commissioner Of Income Tax (Exemption), Has Erred In Facts & In Law In Rejecting The Application Under Section 80G (5) For The Reason That The Trust University Has Made Application For Final Registration Within The Validity Of Provisional Registration & That The Provisional Registration Is Valid Till Ay 2025-26. 3. On The Facts & In Circumstances Of The Case As Well As Law, The Ld. Cit(Exemption) Has Erred In Rejecting Assessee'S Application U/S 80G(5) Filed On 28.03.2023 On The Ground That Assessee Didn'T File The Application Before 30.09.2022 When The Assessee Has Filed The Application In Time As Per The Extension Granted Till 30.09.2023 As Per Circular No.6/2023 Dated 29-05-2023

Section 80G(5) of the Act. While passing the order, the ITAT made the following observations:- “8. In our considered view, the ITAT in the case of CIT-1982, Charitable Trust

BHURABHAI PUNJABHAI PARSANA FOUNDATION,RAJKOT, GUJARAT vs. THE CIT(EXEMPTION) , AHMEDABAD, GUJARAT

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

Bench: Shri Siddhartha Nautiyal (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

Section 80G(5) of the Act. While passing the order, the ITAT made the following observations:- “8. In our considered view, the ITAT in the case of CIT-1982, Charitable Trust

TATAM SEVA SANSTHAN,BHAVNAGAR vs. COMMISSIONER OF INCOME TAX, (EXEMEPTION), AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 80G(5) of the Act. While passing the order, the ITAT made the following observations:- “8. In our considered view, the ITAT in the case of CIT-1982, Charitable Trust

CLEAN TEETH CLEAN MOUTH CHARITABLE TRUST,RAJKOT vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

Charitable Trust vs. CIT(E) Asst.Year –N.A. - 10– registration of Trust under Section 12A of the Act till 30.09.2023. In the case of Tomorrow’s Foundation vs. CIT(E) 160 taxmann.com 174 (Kolkata – Tribunal), while passing the order the Tribunal has held that where assessee had been granted provisional approval under clause (iv) to first proviso to section 80G(5

NANA AND RANDER SUNNI VOHRA MEDICAL AND CHARITABLE TRUST,SURAT vs. COMMISSIONER OF INCOMETAX (EXEMPTION ) AHMEDABAD, AHMRDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

Section 80G(5)(iii) of the Act in Form No. 10AB on 30.03.2023. The assessee / Applicant Trust had been earlier granted or for Nana And Rander Sunni Vohra Medical And Charitable

ADANI KINDERGARTEN EDUCATION FOUNDATION,AHMEDABAD vs. THE CIT(EXEMPTIONS), AHMEDABAD

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

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

Charitable Trust in ITA No. 827/Chennai/2023 in which the ITAT held that timeline prescribed under Clause (iii) of first proviso to Section 80G(5

ADANI EDUCATION FOUNDATION,AHMEDABAD vs. THE CIT(EXEMPTIONS), AHMEDABAD

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

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

Charitable Trust in ITA No. 827/Chennai/2023 in which the ITAT held that timeline prescribed under Clause (iii) of first proviso to Section 80G(5

SHREE STHANAKVASI JAIN SANGH JIVRAJPARK,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

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

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

Charitable Trust vs. CIT(E) in ITA No.116/Rjt/2023, dated 23.02.2024 interpreted the provisions of the Section holding at para 7 to 10.1 of its order as under: “7. We have heard the rival contentions and perused the material on record. 8. It would be useful to reproduce Explanation 3 to Section 80G(5

SHREE VARDHMAN SAMAJ UTKARSH FUND,SABARKANTHA vs. THE CIT(EXEMPTION), AHMEDABAD

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

Bench: DR. BRR Kumar (Vice President), Shri Siddhartha Nautiyal (Judicial Member)

charitable purposes, and had not responded to the final notice issued, the CIT(Exemptions) held that the applicant violated the conditions under section 80G(5)(ii), 80G(5)(iii), and Explanation 3 to section 80G of the Act. As a result, the trust

ARYAGRAM VIRASAT FOUNDATION,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: Na Aryagram Virasat Foundation, Vs. Commissioner Of Income- P No. 300/23, Kanya Gurukul, Tax (Exemption), Nr. Sent Ann School, Nr. Hira Ahmedabad Jain Society, Ramnagar, Sabarmati, Ahmedabad-380005 Pan : Aaqca 9818 H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Devan Kapadia, Ar Revenue By : Shri V. Nandakumar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 21.10.2024 घोषणा की तारीख /Date Of Pronouncement: 25.10.2024

5)(iii), benefit of deduction under section 80G can be claimed. Thus, it could be said that a public religious trust, not meant for the benefit of a particular community, caste or section, will be entitled to claim exemption on its income in the same way as a public charitable

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

5% of total income),\nmaking it eligible for the benefits of Section 80G under the provisions of\nSection 80G(5B). Thus, it was submitted before us that the trust qualifies\nfor Section 80G benefits, as it mainly focuses on charitable

JAYSHREE GOPALLALJI HAVELI CHARITABLE TRUST-UJALVAV,BHAVNAGAR vs. THE CIT (EXEMPTION), AHMEDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.220/Ahd/2025 िनधा"रण वष" /Assessment Year : Na Jayshree Gopallalji Haveli The Cit (Exemption) बनाम/ Charitable Trust-Ujalvav Ahmedabad – 380 015 V/S. At Ujalvav, Umrala Bhavnagar – 364 290 "थायी लेखा सं./Pan: Aaetj 3303 P (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mohit Balani, Ar Revenue By : Shri Alpesh Parmar, Cit-Dr

trust contain elements of religious nature, the same would not disentitle it from approval under section 80G so long as its predominant purpose remains charitable. In that case, it was observed that the statute itself under section 80G(5B) of the Act permits the expenditure of up to 5

RAJVEE FOUNDATION,PATAN vs. THE CIT(EXEMPTION), AHMEDABAD

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.438/Ahd/2025 िनधा"रण वष" /Assessment Year : N.A Rajvee Foundation, The Commissioner Of 8, Yash Kutir Society, बनाम/ Income Tax, V/S. Padamnath Chikadi, (Exemption), Patan-384265. Ahmedabad (Gujarat) "थायी लेखा सं./Pan: Aaetr6780Q अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Kunal P Sanghvi, 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 Passed By The Learned Commissioner Of Income Tax (Exemption), Ahmedabad [Hereinafter Referred To As “Cit(E)”] Dated 26.12.2024, Passed Under Section 80G(5) Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Whereby The Assessee’S Application In Form No. 10Ab For Approval Under Section 80G Was Rejected & The Provisional Approval Earlier Granted Was Cancelled. Rajvee Foundation Vs. Cit(E) Assessment Year N.A 2 Facts Of The Case

Trust v. CIT(E), Ahmedabad (ITA No. 175/Ahd/2023). The CIT(E) concluded that approval under section 80G can be granted only to institutions established wholly for charitable purposes and not where even one object is religious. He also held that section 80G(5B) is only a clarificatory provision and does not override the main condition under section 80G(5

THE BARODA LAKKAD PITHA PUNCH PROPERTY BARODA,VADODARA vs. THE CIT(EXEMPTION), AHMEDABAD

The appeals are allowed for statistical purposes

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

charitable purposes. It was, therefore, urged that the statutory conditions prescribed under clause (vi)(B) of section 12A(1)(ac) were duly satisfied. 11. As regards the second appeal pertaining to the rejection of approval under section 80G(5) of the Act, the AR, by way of written submission, submitted that the dominant and operative objects of the assessee trust

THE BARODA LAKKAD PITHA PUNCH PROPERTY BARODA,VADODARA vs. THE CIT(EXEMPTION), AHMEDABAD

The appeals are allowed for statistical purposes

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

charitable purposes. It was, therefore, urged that the statutory conditions prescribed under clause (vi)(B) of section 12A(1)(ac) were duly satisfied. 11. As regards the second appeal pertaining to the rejection of approval under section 80G(5) of the Act, the AR, by way of written submission, submitted that the dominant and operative objects of the assessee trust

AKSHAT EDUCATION AND CHARITABLE TRUST,ANAND vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

charitable trust registered under the Bombay\nPublic Trusts Act, 1950, vide Registration No. E/3082/Anand dated\n26.09.2013, and is engaged in running various educational institutions\nunder the name Adharshila Vidhyalaya. On 06.02.2024, the appellant filed\nan application in Form No. 10AB before the Ld. CIT(E), Ahmedabad,\nseeking approval under section 80G(5

MAHATMA GANDHI SABARMATI ASHRAM MEMORIAL TRUST(MGSAMT),AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal filed by the Assessee is allowed for statistical purpose…”

Bench: Dr.Brr Kumarshri Tr Senthil Kumar

charitable institutions (Approval under sub-section (5)) - Assessment year 2023-24-Assessee-trust had earlier been granted provisional approval in Form No. 10AC under clause (iv) of first proviso to section 80G