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

cash through inflation of expenses and by obtaining funds in a fraudulent way and by diverting the income for the purposes other than the object of the Trust, it can be reasonably held that assessee violated the basic objects for which trust is created. In view of the same, the activities of the trust cannot be held

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

cash through inflation of expenses and by obtaining funds in a fraudulent way and by diverting the income for the purposes other than the object of the Trust, it can be reasonably held that assessee violated the basic objects for which trust is created. In view of the same, the activities of the trust cannot be held

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

cash through inflation of expenses and by obtaining funds in a fraudulent way and by diverting the income for the purposes other than the object of the Trust, it can be reasonably held that assessee violated the basic objects for which trust is created. In view of the same, the activities of the trust cannot be held

PARUL UNIVERSITY,VADODARA vs. THE DY.CIT,EXEMPTION CIRCLE-1, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

cash through inflation of expenses and by obtaining funds in a fraudulent way and by diverting the income for the purposes other than the object of the Trust, it can be reasonably held that assessee violated the basic objects for which trust is created. In view of the same, the activities of the trust cannot be held

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

cash through inflation of expenses and by obtaining funds in a fraudulent way and by diverting the income for the purposes other than the object of the Trust, it can be reasonably held that assessee violated the basic objects for which trust is created. In view of the same, the activities of the trust cannot be held

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

unexplained cash credit in respect of sale of shares. The order of the Ld. CIT(A) on this issue is, therefore, upheld and the appeal of the Revenue is dismissed. ITA No.769/Ahd/2025 filed by the Assessee 12. The assessee has taken the following grounds in this appeal: - “1. Ld. CIT (A) (NFAC) erred in law and on facts in holding

IDEAL EDUCATION TRUST,VADODARA vs. THE INCOME TAX OFFICER, WARD EXEMPTION, VADODARA

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

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.589/Ahd/2024 "नधा"रण वष" /Assessment Year : 2011-12 Ideal Education Trust The Income Tax Officer 1, Indra Duplex, बनाम/ Ward Exemption, Harni Road, Baroda Vadodara V/S. Baroda – 390 022 (Gujarat) "थायी लेखा सं./Pan:Aaati 5704 P (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Samir Parikh, Ar Revenue By : Smt. Trupti Patel, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 05/09/2024 घोषणा क" तार"ख /Date Of Pronouncement: 10/09/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Of The Ld.Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Ld.Cit(A)” ], Dated 26.02.2024, For The Assessment Year (Ay) 2011-12 Arising Out Of Assessment Order Passed By The Assessing Officer (Hereinafter Referred To As “Ao”) Under Section 143(3) R.W.S. 147 Of The Income Tax Act,1961 [Hereinafter Referred To As “The Act”]. Ideal Education Trust Vs. The Ito-Ward Exemption Asst. Year : 2011-12

unexplained cash credit under section 69A. The addition is confirmed by Hon. CIT(A) not accepting the submission made during the course of appeal proceeding. 3. Appellant Craves leave to add, alter or amend any of the grounds of Appeal mentioned above, either at or before the time of hearing.” Facts of the Case: 3. The assessee is a charitable

LATE SMT. SAVITABEN PATEL EDUCATION CHARITABLE TRUST,ANAND vs. THE ITO, WARD-1, ANAND

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

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Charitable Trust vs. ITO] - 3 – respect of cash deposits of Rs.16,00,000/-and credits of Rs.10,12,398/- in various bank accounts made by A.O as unexplained

DAWOODI BOHRA JAMAT GODHRA,GODHRA vs. THE INCOME TAX OFFICER, WARD-EXEMPTION, VADODARA

In the result, the appeal of the assessee is allowed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1567/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Dawoodi Bohra Jamat Godhra The Income Tax Officer बनाम/ Dawoodi Bohra Masjid Ward Exemption V/S. Vohrawad, Godhra Vadodara Godhra – 389 001 (Gujarat) "थायी लेखा सं./Pan: Aaatd 4476 D (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Ms. Urvashi Sodhan, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05/12/2024 घोषणा की तारीख /Date Of Pronouncement: 09/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

credit U/s 68 of the Act. 3. Both the lower authorities have erred in law and on facts of the appellant's case in holding that cash deposited in bank is unexplained. 4. The charging income tax U/s 115BBE of the Act on addition made U/s 68 of the Act is not justified. 5. The initiation of penalty proceedings

THE JANSEVA TRUST,GODHRA vs. THE INCOME TAX OFFICER, WARD 4(1)(2), VADODARA (NOW INCOME TAX OFFICER, WARD 1, GODHRA), GODHRA

In the result, the appeal of the assessee is allowed for statistical purposes, subject to the above directions

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.851/Ahd/2023 िनधा"रण वष" /Assessment Year : 2017-18 The Janseva Trust The Ito बनाम/ Opp. Gyandeep School Ward-4(1)(1)(2), Vadodara V/S. Nr.Jivanlal Hospital (Now Ito, Ward-1, Godhra – 389 001 (Gujarat) Godhra – 389 001) "थायी लेखा सं./Pan: Aaatt 2888 D (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Ms. Nikhita Bhamblani & Amrin Pathan, Ars Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 27/01/2025 घोषणा की तारीख /Date Of Pronouncement: 29/01/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], Dated 29.08.2023, For The Assessment Year (A.Y.) 2017-18. The Said Appeal Arises From The Assessment Order Passed By The Income Tax Officer (Ito), Ward 4(1)(2), Vadodara [Hereinafter Referred To As “Ao”], Under Section 144 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act)”], On 24.12.2019. The Janseva Trust Vs. Ito Asst. Year : 2017-18

unexplained without appreciating the nature of activities undertaken by the Appellant. 13. The learned CIT(A) erred in fact and in law in confirming the action of learned AO in making addition of cash deposited during the year despite the fact that source of cash deposits was duly explained to the learned AO. 14. Without prejudice to the above

THE FALAHE DARAIN EDUCATION SOCIETY,AHMEDABAD vs. DCIT, CIRCLE-1, EXMP., AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is allowed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

unexplained. 4. Drawing our attention to the facts of the case from the orders of the authorities below, it was pointed out that the assessee was a trust formed for educational and charitable purposes registered u/s.12AA of the Act and also u/s.80G of the Act. During the impugned year, the assessee had received voluntary contribution forming part of corpus

KALOL SEVA SARVJANIK TRUST,MEHSANA vs. ITO (EXEMPTION),, PALANPUR

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

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No. 2295/Ahd/2017 "नधा"रण वष"/Assessment Year: 2013-2014

unexplained cash credit. Appeal to the ld.CIT(A) did not bring any relief to the assessee. 4. Before us, the ld.counsel for the assessee contended that tax consultant of the assessee trust did not advise properly for the requirement to furnish all these details. He filed paper book containing 123 pages, wherein he has annexed profit & loss account, balance sheet

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

unexplained, therefore, the AO has rightly made the addition of the said amount. It is worth here to mention that the AO has made this addition in all the assessment years on the basis of the cash flow statement without granting the carry forward of the closing cash balance at the year end to the opening balance of either subsequent

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

unexplained, therefore, the AO has rightly made the addition of the said amount. It is worth here to mention that the AO has made this addition in all the assessment years on the basis of the cash flow statement without granting the carry forward of the closing cash balance at the year end to the opening balance of either subsequent

THE DCIT, CENTRAL CIRCLE-2, VADODARA vs. M/S. SIGMA INSTITUTE OF TECHNOLOGY AND ENGINEERING,, VADODARA

In the result, appeal filed by the Revenue is partly allowed

Bench: the Hon'ble Settlement Commission.

credits in the undisclosed bank account of the assessee by accepting the explanation of the assessee. ITA No.197/Ahd/2020 [DCIT vs. M/s. Sigma Institute Of Technology And Engineering] A.Y. 2008-09 - 5 – 6. Ground Nos. 1 to 4 raised by the Revenue relate to the issue of unaccounted donations and salary received back in cash. As stated above

ANAND EDUCATION TRUST,AHMEDABAD vs. THE ITO, WARD-1 (EXEMPTIONS), AHMEDABAD

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

charitable trust engaged in running Government-\napproved educational institutions – Shree Panchtirth Vidhyalaya (standards\n1 to 8) and Shree Panchtirth Higher Secondary School (standards 9 to 12).\nBased on AIR information under the Insight Portal, it was observed that the\nassessee had deposited cash aggregating to Rs.1,37,90,000/- during Financial\nYear (FY) 2017-18. The assessee had not filed

SHRI RUSHABHDEV SWETAMBAR MURTIPUJAK JAIN SANGH,AHMEDABAD vs. THE ITO, WARD-2 (EXEMPTION), AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar&Shri Makarand V. Mahadeokar

charitable trust under section 12AA of the Act. The Assessing Officer received information through NMS/Insight database indicating that cash deposits aggregating to Rs. 21,56,720/- and bank interest income of Rs. 1,37,082/- were recorded in certain bank accounts during the financial year relevant to the assessment year under consideration, corresponding to PAN AAATR2081G. According

SUVIDHA EDUCATION TRUST,MEHSANA vs. ITO (EXEMPTION), PALANPUR

In the result the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No. 2409/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2009-2010 Suvidha Education Trust, I.T.O,(Exemption) 7 Maheshweri Society, Vs. Palanpur. Opp. Jyoti Petrol Pump, Mehsana.

charitable trust and engaged in the activity of education. The assessee in the year under consideration has presented addition of ₹ 13,58,001.00 in the building fund account shown on the side of the liability of its balance sheet as on 31 March 2009. On perusal of such addition, the AO was of the view that the assessee has incurred