SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

capital so as to advance the loan. Borrowed funds of the assessee have been utilised to lend loans to the public and the rate of interest charged is with a view to generate profit. xv. The ld. A.R. submitted that the learned assessing officer has held that the assessee is engaged in business activity and denied the exemption under section

DCIT, CENTRAL CIRCLE, BELLARI vs. M/S. NAVODAYA EDUCATION TRUST, RAICHUR

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2009-10

2(15) is applicable to a Trust/Institution which is carrying on activity of advancement of any other object of general public utility and largely deals with cases where there is activity of trade, commerce or business. The ld. CIT(A) was of the view that in the instant case, as the trust is not carrying on any other object

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, , BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No:Aaajk0398K\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

12A of the Act.\n\n8. The ld. D.R. on the other hand, vehemently supported the orders of the authorities below.\n\n9. We have heard the rival submissions and perused the materials available on record. The only issue raised in this appeal is with regard to the denial of the exemption under section 11 of the Act. The brief

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

capital so as to advance the loan. Borrowed\nfunds of the assessee have been utilised to lend loans to the public and\nthe rate of interest charged is with a view to generate profit.\nXv.\nThe ld. A.R. submitted that the learned assessing officer has\nheld that the assessee is engaged in business activity and denied\nthe exemption under section

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No :Aaajk0398K\Nappellant\Nrespondent\N\Nappellant By\Nrespondent By\N: Sri Padamchand Khincha, A.R.\N: Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing\N: 17.09.2025\Ndate Of Pronouncement\N: 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed\Nagainst The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide\Ndin & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For\Nthe Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With\Ndin & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For\Nthe Assessment Year 2015-16 Passed U/S 250 Of The Income Tax\Nact, 1961 (In Short “The Act”). Since The Issues In Both The Appeals\Nare Similar, These Are Clubbed Together, Heard Together And\Ndisposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025\Nfor The Assessment Year 2021-22 For Adjudication. The Assessee\Nhas Raised The Following Grounds Of Appeal:\N\N1. General Ground\N1.

12A of the Act.\n\n8. The ld. D.R. on the other hand, vehemently supported the\norders of the authorities below.\n\n9. We have heard the rival submissions and perused the\nmaterials available on record. The only issue raised in this appeal is\nwith regard to the denial of the exemption under section 11 of the\nAct. The brief

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

section 132A. 50.3 Applicability-These\namendments will take effect from the 1st day of June, 2007.\"\n\n6.2 From the perusal of the section 153D of the Act read with the CBDT\nCircular No. 3 of 2008, dated 12-3-2008, the legislative intent can be gathered\nso far as that the legislature in its highest wisdom made it compulsory

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), QUEENS ROAD, BENGALURU vs. SHRI KEMPAREDDY GOVINDRAJU, DOMLUR, BENGALURU

2, Bengaluru, in F.No.\n51(3)/CIT/CR-2/2017-18 dated 29.12.2017 as per section 153D of the\nAct.\n9. Aggrieved from the above Order, assessee filed appeal before\nthe ld. CIT(A) raising the legal issue as well as on merits of the case.\nThe assessee also filed written submissions on 28.01.2022 in detail\nwhich has been incorporated

M/S. VIJAYANAGAR EDUCATIONAL TRUST,BENGALURU vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), BENGALURU

In the result appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2019-20

2) act, 2019 there was an amendment to the above section wherein one more condition is included which provides that if the trust or institution has not complied with the requirement of any other law, order, directions decree then also such a registration can be cancelled. 31. The First Reason for cancellation is that the assessee trust has made amendment

SHRI. KEMPAREDDY GOVINDRAJ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BENGALURU

2, Bengaluru, in F.No. \n51(3)/CIT/CR-2/2017-18 dated 29.12.2017 as per section 153D of the \nAct.\n\n9. Aggrieved from the above Order, assessee filed appeal before \nthe ld. CIT(A) raising the legal issue as well as on merits of the case. \nThe assessee also filed written submissions on 28.01.2022 in detail \nwhich has been incorporated

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

2 has observed as under:\n13. In another words, it was emphasised that the approval was\ngranted without examining the assessment record or the search\nmaterial. The relevant observations made in this behalf by the Tribunal\nin the impugned order are extracted hereafter:\n\"17.1 However, in the present case, we have no hesitation in\nstating that there is complete

SHRI. KEMPAREDDY GOVINDRAJ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), BENGALURU

In the result the appeals of the assessee in ITA No’s 1022 to \n1024/ Bang/ 2024, for the

2 and AYs 2014-15, 2015-16 & 2016-17 - Ground 3: Search \nconducted on the appellant u/s 132 is not legal and valid: \n\nThis ground raised by the appellant is mainly on account of the legality of the search conducted \nunder section 132 of the Income Tax Act and hence appellant denies himself liable to be assessed \nunder section

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(3), BENGLAURU vs. SHRI KEMPAREDDY GOVINDRAJU, DOMLUR, BENGALURU

In the result the appeals of the assessee in ITA No’s 1022 to 1024/ Bang/ 2024, for the Assessment Years 2014-15, 2015-16 and 2016-17 are allowed and the appeals of the Revenue in ITA Nos

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

12A of the Wealth Tax Act. iii. The CIT(A) also consequently failed to appreciate that any valuation adopted for the purposes of assessment has to be solely based on such a report. Consequently, additions which are made not based on a valid report are liable to be deleted on the facts and circumstances of ITA Nos.1021 to 1024/Bang/2024

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

2 students for Rs.67.5 lakh each\nis supported by the seized materials which is not merely an\nextrapolation.\n7.5 The AO regarding the deletion of the addition made in earlier year\nby the Tribunal held that the facts are distinguishable as in the present\ncase, the receipt of capitation fee has been corroborated by the\nmaterials seized from the agent

DCIT, CENTRAL CIRCLE-1(4), BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

2 students for Rs.67.5 lakh each\nis supported by the seized materials which is not merely an\nextrapolation.\n7.5\nThe AO regarding the deletion of the addition made in earlier year\nby the Tribunal held that the facts are distinguishable as in the present\ncase, the receipt of capitation fee has been corroborated by the\nmaterials seized from the agent

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1(4), BENGALURU, BENGALURU vs. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD), KOLAR

2 students for Rs.67.5 lakh each\nis supported by the seized materials which is not merely an\nextrapolation.\n7.5 The AO regarding the deletion of the addition made in earlier year\nby the Tribunal held that the facts are distinguishable as in the present\ncase, the receipt of capitation fee has been corroborated by the\nmaterials seized from the agent

SHRI. KEMPAREDDY GOVINDRAJ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3) , BENGALURU

In the result the appeals of the assessee in ITA No’s 1022 to\n1024/ Bang/ 2024, for the

2, Bengaluru, in F.No.\n51(3)/CIT/CR-2/2017-18 dated 29.12.2017 as per section 153D of the\nAct.\n\n9. Aggrieved from the above Order, assessee filed appeal before\nthe ld. CIT(A) raising the legal issue as well as on merits of the case.\nThe assessee also filed written submissions on 28.01.2022 in detail\nwhich has been incorporated

DCIT, CENTRAL CIRCLE-1(4), BENGALURU, BENGALURU vs. DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES, KOLAR

In the result, the appeal of the assessee is hereby partly allowed

2 students for Rs.67.5 lakh each\nis supported by the seized materials which is not merely an\nextrapolation.\n7.5\nThe AO regarding the deletion of the addition made in earlier year\nby the Tribunal held that the facts are distinguishable as in the present\ncase, the receipt of capitation fee has been corroborated by the\nmaterials seized from the agent

M/S. SRI DEVARAJ URS EDUCATIONAL TRUST FOR BACKWARD CLASSES (REGD),KOLAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed

2 students for Rs.67.5 lakh each\nis supported by the seized materials which is not merely an\nextrapolation.\n7.5 The AO regarding the deletion of the addition made in earlier year\nby the Tribunal held that the facts are distinguishable as in the present\ncase, the receipt of capitation fee has been corroborated by the\nmaterials seized from the agent