DEPUTY COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST,, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ADDL. COMMISSIONER OF INCOME TAX, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

M/S. SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

M/S. SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

M/S. SADHU SINGH HAMDARD TRUST,JALANDHAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

THE ASSISTANT COMMISSIONER OF INCOME TAX,JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

THE ASSISTANT COMMISSIONER OF INCOME TAX,JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

THE DCIT, JALANDHAR vs. M/S. SADHU SINGH HAMDARD TRUST, JALANDHAR

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35- 37) - ITO v. Human Resource Development and Management Trust: (2011) 47 SOT 85 (Cuttack) (refer para 23) 6. On perusal of the aforesaid, it is respectfully submitted that merely because payment is made to persons specified in section 13(3), it cannot be alleged that there is violation of section 13(1)(c) of the Act. The onus

M/S SANT BABA BHAG SINGH MEMORIAL CHARITABLE SOCIETY,JALANDHAR vs. D.C.I.T, CIRCLE - 1 (EXEMPTION), CHANDIGARH

In the result, the assessee’s appeal is partly allowed

Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 432/(Asr)/2017 Assessment Year: 2014-15

35,57,500/-, received by assessee society, from identified persons, were anonymous donations, liable to tax under section 115BBC. 2. That having held so, the ld. CIT(A), grossly misconstrued the relevant provisions of law, to hold that the impugned corpus donation, once held to be taxable U/S.115BBC, was still to 3 Sant Baba Bhag Singh M. C. Society

MESERS PEER PANCHAL EDUCATIONAL AND WELFARE TRUST ,JAMMU AND KASHMIR vs. COMMISSIONER OF INCOME TAX(EXEMPTIONS), CHANDIGARH

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

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

10 Peer Panchal Educational And Welfare Trust v. CIT(E) From the above chart it is quite clear that the surplus generated over revenue expenditure is exclusively spent for construction of the trust building for furtherance of the objects of the trust. During the year referred by the Ld. CIT(E) that assessee has generated surplus

SHIROMANI GURDWARA PARBANDHAK COMMITTEE vs. COMMISSIONER OF INCOME TAX-I,

In the result the appeal of the Assessee is allowed

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenav.S. Cit – I Shirmoni Gurdwara Parbandhak Committee Amritsar Teja Singh Mundri Hall Sri Amritsar Pan:Aants1981K (Appellant) (Respondent)

35), Universities (2), Medical Colleges (1), Dental College (1), Nursing College (1), Engineering Colleges (2) & Polytechnic College (1), Hospitals, Lungars, Sarais, Educational Aid, Aid to Poor, Medical Aid, Aid for Historical Buildings, Cancer Aid, Aid for Natural Calamities like Earthquakes/Droughts, Aid for Social Awareness like drugs, dowry etc. b. Further, it is a publicly known fact that the aforesaid charitable

MESERS BAJAJ EDUCATIONAL SOCIETY,LUDHIANA vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CHANDIGARH

The appeal of the assessee is allowed

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

10(23C) of the Act) to another code (Section 12AA of the Act) despite the fact that the objects of the Appellant Society are not restricted to the Educational Activities alone and despite the fact that all the evidences with regard to the above are a part of Record of the Ld. CIT. 6. That the Learned Commissioner of Income

RAHUL KHINDRI,AMRITSAR vs. INCOME TAX OFFICER WARD-1 (1), AMRITSAR

In the result, Assessee’s appeal is allowed

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 37/Asr/2024 निर्धारण वर्ा / Assessment Year : 2021-22 Rahul Khindri, बनाम A.O., Cpc, 2157, Bazar Sirki Banda, Banglore Katra Dullo, Amritsar Indra Nagar, 143001 स्थधयी लेखध सं./Pan No: Apfpk9150F अपीलधथी/Appellant प्रत्यथी/Respondent ( Hybrid Hearing ) निर्धाररती की ओर से/Assessee By : Shri Rohit Kapoor, Ca रधजस्व की ओर से/ Revenue By : Mrs. Neelam Sharma, Sr.Dr सुिवधई की तधरीख/Date Of Hearing : 23.12.2024 उदघोर्णध की तधरीख/Date Of Pronouncement : 10.03.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 31.07.2023 Passed By Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi. 2. Grounds Of Appeal Are As Under:- 1. That The Ld. C1T(A) Vide Order U/S 250(6) Dated 31.07.2023 Has Erred In Confirming The Action Of The Ao In Not Providing The Benefit Of Lower Tax As Per Section 115Bac Due To The Fact That Form 10 Ie Was Not Filed Before The Due Date Of Filing Of Return U/S 139(1) I.E. 31.12.2021. 37-Asr-2024 Rahul Khindri, Amritsar 2

35 dated 19.08.2022 challenging the disallowance made by the Ld. ADIT (CPC). However, the Ld. CIT(A) passed an order u/s 250 on 31.07.2023 dismissing the appeal. 8. Subsequently, the appellant filed an appeal before ITAT Amritsar Bench vide from 36 on 30.05.2024 against the order of CIT (A) on the following grounds: - 9. SUBMISSIONS IN RESPECT OF GROUND

M/S. LEH NUTRITION PROJECT,,LEH LADKH vs. THE DY. COMMISSIONER OF INCOME-TAX, SRINAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

35,623 3 Leh Nutrition Project v. DCIT 6. That Id CIT(A) has wrongly ignored that no addition was ever made in the case of appellant since inception as ‘NGO’ on this issue, by Income Tax Department. 7. That order of Ld AO & Ld CIT (A) is bad in law, as well as, on facts. 8. That appellant craves

M/S SPRING DEW PUBLIC SCHOOL,JAGRAON vs. COMMISSIONER OF INCOME TAX (EXAMPTION), CHANDIGARH

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

Bench: Sh. Sanjay Arora & Sh. N.K.Choudhryita No.492(Asr)/2017 Assessment Year:

Charitable Activity. 3. That the Learned Commissioner of Income Tax has erred in holding that the Appellant has not been providing quality educational services to the Society. 4. That, the Learned Commissioner of Income Tax has erred in holding that an Appellant cannot shift from one code (Section 10(23C) of the Act) to another code (Section 12AA

ASSIATANT COMMISSIONER OF INCOME TAX PHAGWARA CIRCLE, PHAGWARA vs. SHRI HARMESH KUMAR, PHILLAUR

In the result, these appeals are allowed for statistical purposes

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

10 based on the documents impounded which pertain to those years and therefore, making again an addition of Rs 5 crore on lump sum basis would amount to double taxation of the same income, which is against the basic principle of taxation that same income cannot be taxed twice. 4.19 Accordingly, considering the instructions of the CBDT on this issue