ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

Bench: Shri George George K & Shri Waseem Ahmed

1) Nothing contained in section 11 or section 12 shall operate so as to exclude from the total income of the previous year of the person in receipt thereof - . Page 8 of 23 (d) in the case of a trust for chartable or religious purposes or a charitable

ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. CMR JNANADHARA TRUST, BENGALURU

In the result, the appeal filed by the revenue is hereby dismissed

Bench: Shri George George K & Shri Waseem Ahmed

1) Nothing contained in section 11 or section 12 shall operate so as to exclude from the total income of the previous year of the person in receipt thereof - . Page 8 of 23 (d) in the case of a trust for chartable or religious purposes or a charitable

KARNATAKA CHINMAYA SEVA TRUST,BENGALURU vs. DCIT-(EXEMPTIONS) CIRCLE-1, BANGALORE

In the result, the appeal of the assessee in ITA No

charitable activities. Therefore, Assessing Officer is\ndirected to give exemption under Section 11 in respect of the pharmacy\ncollection as well.\n13. From the above it becomes clear that the decision of treating the pharmacy\nincome as eligible for exemption u/s.11 is taken on the basis that the running of\nthe pharmacy within the hospital premises is an integral part

KARNATAKA CHINMAYA SEVA TRUST,BENGALURU vs. DCIT-(EXEMPTIONS) CIRCLE-1, BANGALORE

In the result, the appeal of the assessee in ITA No

trust.", "held": "The Tribunal held that the assessee is entitled to accumulate 15% of gross voluntary contributions under Section 11(1)(a), not 15% of the net surplus. Regarding the pharmacy income, the Tribunal ruled that it is an integral part of the hospital's charitable activities and thus eligible for exemption under Section 11, as the conditions under Section

SRI SRINIVASA TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1), RMV Extension, Bangalore. Bangalore. . PAN – AABTS 8147 B APPELLANT RESPONDENT Assessee by : Shri Siva Prasad Reddy & Shri Balachandran, Advocate, Revenue by : Ms. Nandini Das, CIT (DR) Date of hearing : 19.12.2025 Date of Pronouncement : 18.02.2025 O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These appeals filed by the assessee are against the order passed

SRI SRINIVASA TRUST,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1), RMV Extension, Bangalore. Bangalore. . PAN – AABTS 8147 B APPELLANT RESPONDENT Assessee by : Shri Siva Prasad Reddy & Shri Balachandran, Advocate, Revenue by : Ms. Nandini Das, CIT (DR) Date of hearing : 19.12.2025 Date of Pronouncement : 18.02.2025 O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These appeals filed by the assessee are against the order passed

DCIT, BANGALORE vs. M/S B S & G FOUNDATION,, BANGALORE

In the result, Revenue’s appeal for asst

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazthe Dy. Commissioner Of Income-Tax (Exemptions), Bengaluru. . Appellant Vs. M/S B S & G Foundation, 502, 2Nd Floor, 5Th ‘C’ Main, 5Th Cross, 2Nd Block, Hrbr Layout, Kalyannagar, Bangalore. . Respondent Pan – Aaatb6131D. Appellant By : Smt. Padmameenakshhi, Jcit Respondent By : Shri R.T Balasubramanyam, C.A Date Of Hearing : 28-9-2017 Date Of Pronouncement : 4-10-2017 O R D E R

trust or institution on the value of assets which has already been allowed ITA No.884/B/16 7 as application of income u/s 11(1) by inserting sub- section (6) of Section 11, w.e.f 01.04.2015, such amendment cannot be construed as effective prospectively inasmuch as in accordance with the ratio laid down by the Hon'ble Supreme Court in the case

SRI. MARAMMA TEMPLE SEVA TRUST,BANGALORE vs. CIT, BANGALORE

In the result, appeal of the assessee is allowed

Bench: Smt. Asha Vijayaraghavan & Shri. Abraham P. Georgei.T.A No818/Bang/2015 (Assessment Year : Na) Sri Maramma Temple Seva Trust, No.11, Maramma Temple Street, 1St Main Road, Vyalikaval, Bengaluru 560 003 .. Appellant Pan : Aants4131R V. Commissioner Of Income-Tax (E), Bengaluru .. Respondent Assessee By : None Revenue By : Shri. Sudhakar Rao, Cit – Dr-I Heard On : 21.10.2015 Pronounced On : 30.10.2015 O R D E R Per Abraham P. George:

d) would be applicable to a trust which is either for charitable purposes or religious purposes or partly charitable purposes and partly religious. Hence it can be stated that if a charitable trust is established only for the benefit of any particular religious community or caste, then the provisions of s. 11 would not be applicable. But in the case

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

Charitable Trust, 103 taxmann.com 419 and also the decision of the Chennai Bench of the Tribunal in the case of Shanmugham Trust [2024] 165 taxmann.com 669. ITA No.2006 /Bang/2019 Page 19 of 37 11. With respect to the violation of the provisions of section 13(1)(d

ABHERAJ BALDOTA FOUNDATION ,HOSPET vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , BELLARY

In the result, both the appeals of the assessee are dismissed

Bench: Shri B.R Baskaran & Smt. Beena Pillai

trust. Sub-clause of 11(2) permits the assessee to accumulate some amount up to a period not exceeding 10 years. Section 11(3) of the Act deals with the consequences if the amount accumulated is not utilised for the specified purposes. Section 11(3) is extracted here for immediate reference "Section 11(3): Any income referred

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BANGALORE

d) the trust or institution established for charitable purpose created or established after the\ncommencement of this Act, has applied any part of its income for the benefit of any particular\nreligious community or caste; or\n(e) any activity being carried out by the trust or institution-\n(1) is not genuine; or\n(ii) is not being carried

M/S. RUKMINI EDUCATIONAL CHARITABLE TRUST,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL , BENGALURU

d) the trust or institution established for charitable purpose created or\nestablished after the commencement of this Act, has applied any part of its\nincome for the benefit of any particular religious community or caste; or\n(e) any activity being carried out by the trust or institution\n(1) is not genuine; or\n(ii) is not being carried

SHRI HINGULAMBIKA EDUCATION SOCIETY,GULBARGA vs. ITO (EXEMPTIONS), WARD-1, KALBURGI

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2020-21

1 of 2015 : dated 21/1/2015. It was this anomaly, which was cured by bringing in the first proviso to Section 12A (2), This proviso, even as avowed by the above quoted Memorandum explaining the provisions of the Finance (No. 2) Bill, has sought to remedy the said unintended hardship visiting Trusts and Institutions. It has supplied the aforesaid omission

CHITRADURGA ZILLA REDDY JANA SANGH(R),CHITRADURGA vs. INCOME TAX OFFICER, WARD-1 EXEMPTION, HUBLI

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

D E R PER KESHAV DUBEY, JUDICIAL MEMBER: This appeal at the instant of the assessee is directed against the order of ld. Addl/JCIT(A)-7, Kolkata dated 2.4.2025 vide DIN and Order No. ITBA/APL/S/250/2025-26/1075426187(1) passed u/s. 250 of the Income Tax Act, 1961 (in short “the Act”) for the AY 2017-18. 2. The Assessee has raised

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

In the result, the grounds raised by the assessee in both the appeals\nare allowed except the limitation ground

1)\nTotal cost of acquisition (A+B+C+D)\nDevelopment cost for formation of layout (road, drainage, water supply, parks etc)\nBoard service charges at 10% on (F)\nInterest charged by the Board at 12.75% p.a on (F)\n(J)\nTotal cost of development (F+(+1)\n(K)\nTotal cost of acquisition and development |(E)- (J)]\n36. Once the total

THE ASST.COMMISSIONER OF INCOME TAX - (EXEMPTIONS ) CIRCLE - 1, MANGALURU vs. M/S A. SHAMA RAO FOUNDATION, MANGALURU

In the result, appeal of the Revenue is dismissed

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm I.T.A. No.1464/Bang/2018 Assessment Year : 2015-16 The Assistant Commissioner Of Vs. M/S. A. Shama Rao Foundation, Income-Tax (Exemptions), Circle- 13-2-116, Hotel Srinivas Building, 1, Mangaluru G.H.S. Road, Mangaluru-575 001. [Pan:Aaata 1629 B] (Revenue-Appellant) (Assessee -Respondent) Revenue By Shri Pradeep Kumar, Cit(Dr) Assessee By Shri V. Srinivasan, Adv. Date Of Hearing 09/11/2020 Date Of Pronouncement 03/12/2020 O R D E R

charitable trust is not prohibited until the 2 I.T.A. No.1464/Bang/2018 amendment to section 11(1)(d) by inserting an Explanation

SADIYA EDUCATIONAL AND CHARITABLE TRUST vs. CIT,

In the result, the assessee's appeals are allowed

Bench: Smt. P. Madhavi Devi & Shri Jason P. Boazi.T. A. Nos.422 & 1632/Bang/2013 M/S. Sadiya Educational & Charitable Trust, Mattadgadde Road, Sadiya Nagar, Shiralkoppa-577 428 …. Appellant.

d) would embody a restrictive purpose of religious activities only. Similarly, assistance by the respondent-trust to the needy and poor for religious activities would not divest the trust of its altruist character. 41..................................... 42. ................................... 43.Thus, the second issue which arises for our consideration and decision is, whether the respondent-trust is a charitable and religious trust only

M/S. NORTH WESTERN KARNATAKA ROAD TRANSPORT CORPORATION,HUBLI vs. JOINT COMMISSIONER OF INCOME TAX (EXEMPTION), HUBLI

In the result, the assessee's appeals for Assessment Years 2006-07 &

Bench: Shri Jason P Boaz & Shri Lalit Kumar

D E R Per Shri Jason P Boaz, A.M. : These appeals by the assessee are directed against the separate orders of Commissioner of Income Tax (Appeals), Hubli dt.29.09.2016 for the Assessment Years 2006-07 & 2012-13. 2. Briefly stated, the facts of the case are as under :- 2.1 The assessee is a corporation established under

M/S GOKULA EDUCATION FOUNDATION MEDICAL ,BANGALORE vs. ADDITIONAL DIRECTOR OF INCOME TAX RANGE-17 , BANGALORE

In the result, appeal of the assessee is partly allowed

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy Sassessment Year : 2011-12

section 11(1)(d). (ii) Copies of ledger accounts and utilization certificate submitted before the CIT(A) are not reconciling. 27. The contention of the assessee is that the grants sanction are tracked separately to ensure that the grants are applied for intended purposes as per the conditions stipulated by the grants sanctioning authority. Considering the arguments of both