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 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

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

GUJARAT TECHNOLOGICAL UNIVERSITY,,AHMEDABAD, GUJARAT vs. COMMISSIONER OF INCOME TAX, EXEMPTION, AHMEDABAD, GUJARAT

In the result, the above ground of appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

reassessment proceedings u/s 147 of the Act. 4. The learned CIT(E) erred in fact and in law in invoking revision power u/s 263 of the Act on an issue of allowability of exemption u/s 11 of the Act despite the fact that proceeding u/s 263 cannot be initiated on debatable issue. Gujarat Technological University vs. CIT(E) Asst. Year

SEQUEL LOGISTICS PRIVATE LIMITED,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-3, 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)

reassessment order passed by the Ld. A.O. is neither erroneous nor prejudicial to the interest of Revenue. Since the Ld. A.O. considered the fact of the case in its entirety, raised queries in respect of the deduction claimed u/s. 80G (Chapter VI-A of the Act) on the CSR expenditure paid to H.N. Safal Foundation, which has valid exemption certificate

SHRI SHENALMA GAUSHALA TRUST,BANASKANTHA vs. THE CIT(EXEMPTION), AHMEDABAD

Appeals are allowed for statistical\npurposes

charitable in nature, aimed\nat running a gaushala for the welfare, upkeep, and treatment of stray cattle\nand other animals, which are in furtherance of public and religious utility. It\nwas submitted that the trust operates from a remote rural location where\naccess to reliable internet infrastructure is severely limited. Consequently, the\ntrustees, being laypersons not well-versed with technical

SHRI SHENALMA GAUSHALA TRUST,BANASKANTHA vs. THE CIT(EXEMPTION), AHMEDABAD

Appeals are allowed for statistical\npurposes

charitable in nature, aimed\nat running a gaushala for the welfare, upkeep, and treatment of stray cattle\nand other animals, which are in furtherance of public and religious utility. It\nwas submitted that the trust operates from a remote rural location where\naccess to reliable internet infrastructure is severely limited. Consequently, the\ntrustees, being laypersons not well-versed with technical

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

Trust vs. ITO Asst. Year : 2017-18 7.8. In the interest of justice and fair play, and considering the charitable nature of the assessee’s activities, the matter is remanded back to the file of the AO for fresh adjudication. The assessee is directed to fully cooperate with the reassessment

BANKIM EDUCATION TRUST,DAHOD vs. THE ITO, WARD-EXEMPTION, VADODARA

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

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Charitable Education Ward -Exemption, Trust] Vs Vadodara. 9, Nilam Society, Station (Respondent) Road, Dahod - 389151 Gujarat PAN: AABTB1528K (Appellant) Assessee by: Shri Divyakant Parikh, A.R. Revenue by: Shri R P Rastogi, CIT-D.R. Date of hearing : 24-09-2025 Date of pronouncement : 14-10-2025 आदेश/ORDER PER : NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER This appeal is filed

HEALTH FOUNDATION & RESEARCH CENTRE,DAHOD vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2, EXEMPTION, AHMEDABAD

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

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.516/Ahd/2023 "नधा"रण वष" /Assessment Year : 2011-12 Health Foundation & The Acit बनाम/ Research Centre Circle-2 (Exemption) Gf Post Box No.156 Ahmedabad-380 015 V/S. Sheth Shri Girdharlal Marg Raliyati Road, Dahold – 389 151 (Gujarat) "थायी लेखा सं./Pan: Aaath 0867 J अपीलाथ"/ (Appellant) ….. "" यथ"/ (Respondent) Assessee By : Shri Sakar Sharma, Ar Revenue By : Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 16/07/2024 घोषणा क" तार"ख /Date Of Pronouncement: 23/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Dated 08/05/2023 Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “The Ld.Cit(A)” In Short], Arising Out Of The Assessment Order Dated 19/12/2018 Passed By The Assessing Officer (Ao) Under Section 143(3) R.W.S. 147 Of The Health Foundation & Research Centre Vs. Acit Asst. Year : 2011-12

Charitable Trust. 4. The Ld. CIT(A)-NFAC erred on facts and in law in not adjudicating ground relating to validity of assessment without issuing any show cause regarding applicability of provisions of section 13(1)(c)(ii) when no adverse inference is warranted under the said provision. Health Foundation & Research Centre vs. ACIT Asst. Year

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

SUNIL PIYUSH SHAH,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. -THE ITO, WARD-5(3)(2), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Ms. Suchitra Kambleassessment Year 2019-20

reassessment order contains no finding invoking section 270A(9) or identifying circumstances of misreporting. The penalty notice is templated and conclusory, and cannot form the basis for denying immunity. 7. That the voluntary payments made by the Appellant of Rs.29,490 (on 27.02.2025) and Rs.8,669 (on 15.08.2025), were made voluntarily without prejudice to avoid hardship, and are liable

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

SATTARBHAI SULEMANBHAI MANSURI,SABARKANTHA vs. THE ITO, WARD-3, HIMATNAGAR

In the result, the appeal is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2014-15 Mr.Sattarbhai Sulemanbhai Mansuri Ito,Ward-3 Anjumarstrit Narth Gulam Floor Factri Vs. Himatnagar. Sarvoday Soc, Polo Ground Himatnagar Sabarkantha 383 001. (Applicant) (Responent) : Shri Varis Isani, Advocate Assessee By : Shri Ravindra, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 06/05/2025 आदेश आदेश/O R D E R आदेश आदेश

reassessment under section 143(3) r.w.s. 147 of the Act computing a total income of Rs.24,26,232/- by making an addition of Rs.22,02,858/- towards long-term capital gain under section 50C, adopting the stamp duty value of Rs.1,12,37,120/- as the deemed sale consideration. The assessee’s 1/5th share was determined at Rs.22

SHRI SHAMLAJI AAROGYA SEVA TRUST,GODHRA vs. THE PR. CIT (CENTRAL), SURAT AT -VADODARA

In the result, the appeal of the Assessee is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.138/Ahd/2022 "नधा"रण वष" /Assessment Year : 2017-18 Shri Shamlaji Aarogya Seva Trust The Pr.Cit (Central) बनाम/ Kanelav Road Surat At Vadodara Dhahod Road V/S. Godhra – 389 001 "थायी लेखा सं./Pan: अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Tushar Hemani, Sr.Advocate & Shri Parimalsinh B. Parmar, Ar Revenue By : Shri H. Phani Raju, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 29/08/2024 घोषणा क" तार"ख /Date Of Pronouncement: 04 /09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Passed By The Ld.Principal Commissioner Of Income Tax (Central), Surat [Hereinafter Referred To As "Pcit"] Under Section 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act"], For The Assessment Year (Ay) 2017-18, Wherein The Pcit Held That The Assessment Order Passed By The Assessing Officer (Hereinafter Referred To As “Ao”) Under Section 143(3) Of The Act, Dated 16.11.2019, Was Erroneous & Prejudicial To The Interests Of

charitable purposes or for the benefit of specified persons disentitles the trust from claiming exemption. However, we restrict the scope of this appeal, without going into merits of eligibility of exemption u/s.11 of the Act, to Ld.PCIT’s invocation of section 263 of the Act. 7.4. The diversion of funds collected in the name of the trust and from debit

GMDC SCIENCE & RESEARCH CENTRE,,AHMEDABAD vs. THE INCOME TAX OFFICER (EXEMPTION),, PALANPUR

In the result, the appeal filed by the assessee is Allowed for Statistical purpose

Bench: Dr. Brr Kumar & Shri T.R. Senthil Kumar

charitable or religious purposes within the time allowed shall be deemed to be the income of such person of the previous year. The appellants income held under trust would have to be arrived at in the normal commercial manner without reference to the provisions which are attracted by other regular sections of Income tax Act. Therefore, I am inclined

GMDC SCIENCE & RESEARCH CENTRE,,AHMEDABAD vs. THE INCOME TAX OFFICER (EXEMPTION),, PALANPUR

In the result, the appeal filed by the assessee is Allowed for Statistical purpose

Bench: Dr. Brr Kumar & Shri T.R. Senthil Kumar

charitable or religious purposes within the time allowed shall be deemed to be the income of such person of the previous year. The appellants income held under trust would have to be arrived at in the normal commercial manner without reference to the provisions which are attracted by other regular sections of Income tax Act. Therefore, I am inclined

GUJARAT MINERAL DEVELOPMENT CORPORATION LIMITED,KHANJI BHAVAN vs. PR. COMMISSIONER OF INCOME TAX-1, AAYAKAR BHAWAN(VEJALPUR), AHMEDABAD

In the result, the appeal filed by the assessee is allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2020-21

charitable institutions, which were distinct from the statutory CSR obligation. The AR relied on the decision of Coordinate Bench in case of Gujarat State Financial Services Ltd. v. DCIT [2025] 174 taxmann.com 461 (ITAT Ahmedabad), where it was held that section 80G(2)(a)(iiihk)/(iiihl) bars deduction only for donations to Swachh Bharat Kosh and Clean Ganga Fund