SRI ASHVALAYANA VRUNDA,BANGALORE vs. ITO, EXEMPTIONS, BANGALORE

In the result, the appeals filed by the assessee-trust are allowed

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

section 80G throughout the period after April 1, 2004, with all consequential benefits.” 23. The CIT(E) has relied on Kasyapa Veda Research Foundation v CIT [2011] 12 taxmann.com 286 (Cochin) to hold that Vedas are religious scriptures and Vedic Study is a 20 ITA Nos.1084-1085/Bang/2022 Sri Ashvalayana Vrunda study of Hindu religion or religious instruction. The said decision

SRI ASHVALAYANA VRUNDA,BANGALORE vs. ITO, EXEMPTIONS, BANGALORE

In the result, the appeals filed by the assessee-trust are allowed

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

section 80G throughout the period after April 1, 2004, with all consequential benefits.” 23. The CIT(E) has relied on Kasyapa Veda Research Foundation v CIT [2011] 12 taxmann.com 286 (Cochin) to hold that Vedas are religious scriptures and Vedic Study is a 20 ITA Nos.1084-1085/Bang/2022 Sri Ashvalayana Vrunda study of Hindu religion or religious instruction. The said decision

SHROUTA VIJNAM GURUKULAM,MANGALORE vs. INCOME TAX OFFICER, WARD-1, EXEMPTIONS, MANGALORE

In the result, the appeals filed by the assessee-trust are allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : Na M/S. Shrouta Vijnan Gurukulam, Vs. Ito (Exemptions), 1 Nidagod, Targod B. O. Ward – 1, Arasapur, Mangaluru. Uttara Kannada – 561 402. Pan : Aants 0655 A Appellant Respondent Assessee By : Shri Prakash S Hegde, Ca Revenue By : Shri. D. K. Mishra, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 20.05.2024 Date Of Pronouncement : 21.05.2024 O R D E R Per George George K: This Appeal At The Instance Of The Assessee Is Directed Against The Cit(E)’S Order Dated 22.02.2024 Rejecting The Assessee’S Application Seeking Approval Under Section 80G Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’).

127 to 157 of paper book] demonstrates the charitable activities carried on by the assessee Trust. Thus the activities carried on by the assesseeTrust are CHARITABLE in the nature of education, relief of poor and not RELIGIOUS as concluded by the CIT(E). In view of the above, the impugned findings of the CIT(E) that the assessee-trust

INDEPENDENT AND PUBLIC SPIRITED MEDIA FOUNDATION ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, (CENTRAL), BENGALURU

In the result appeal of the assessee is dismissed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : Na

CHARITABLE TRUST [2019] 109 TAXMANN.COM 258 / 267 TAXMAN 16 ( BOM) was upheld. Thus, he held that whole the trust cannot be held to be non-genuine, and the registration cannot be cancelled. 30. Thus, he submitted that the order passed by the learned CIT is not sustainable cancelling the registration granted to the assessee trust under section

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

127 ITR 378 wherein it was held as under: Undoubtedly, sub-section (4) of section 11 specifically lays the mode of determination of the income of the business undertaking of a trust. A similar provision is not to be found with regard to the other income of the trust. By an inferential process, it could be said that that mode

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

127 ITR 378 wherein it was held as under: Undoubtedly, sub-section (4) of section 11 specifically lays the mode of determination of the income of the business undertaking of a trust. A similar provision is not to be found with regard to the other income of the trust. By an inferential process, it could be said that that mode

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

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

charitable trust fund for the purchase of property in the name of trustees of huge amount of approx. Rs.115 crores by the then trustees for purchase of property in their own name by utilising the fund of the trust. During the search statement of Mr. M. Vasu, who is the DGM (Finance) confirmed that the property was purchased

M/S. ISLAMIC ACADEMY OF EDUCATION,MANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX(CENTRAL), BANGALORE

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

charitable object of imparting education. Soon after formation of the trust, the assessee has been granted registration u/s 12A of the Act, vide No. Accts-718/10A/VOL.BII/1-53-92/CIT-III dated 04/06/1992 with effect from the date of formation of the trust by the learned Commissioner of Income-tax, Karnataka III, Bangalore. This registration was granted under the applicable provisions of section

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

charitable purpose. 16. What survives to be determined is whether any of BIS's activities fall within the latter and larger category of "involved in the carrying on of any activity of rendering any service in relation to any trade, commerce or business". The expressions "any activity," "rendering any service" and "in relation to any trade, commerce or business" imply

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1,, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

charitable purpose. 16. What survives to be determined is whether any of BIS's activities fall within the latter and larger category of "involved in the carrying on of any activity of rendering any service in relation to any trade, commerce or business". The expressions "any activity," "rendering any service" and "in relation to any trade, commerce or business" imply

M/S. UDUPI NIRMITHI KENDRA,UDUPI vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS) CIRCLE-1, MANGALORE

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

charitable purpose. 16. What survives to be determined is whether any of BIS's activities fall within the latter and larger category of "involved in the carrying on of any activity of rendering any service in relation to any trade, commerce or business". The expressions "any activity," "rendering any service" and "in relation to any trade, commerce or business" imply

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

charitable purpose. 16. What survives to be determined is whether any of BIS's activities fall within the latter and larger category of "involved in the carrying on of any activity of rendering any service in relation to any trade, commerce or business". The expressions "any activity," "rendering any service" and "in relation to any trade, commerce or business" imply

M/S. DAKSHINA KANNADA NIRMITHI KENDRA,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE -1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

charitable purpose. 16. What survives to be determined is whether any of BIS's activities fall within the latter and larger category of "involved in the carrying on of any activity of rendering any service in relation to any trade, commerce or business". The expressions "any activity," "rendering any service" and "in relation to any trade, commerce or business" imply

M/S. UDUPI NIRMITHI KEDRA,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE - 1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

charitable purpose. 16. What survives to be determined is whether any of BIS's activities fall within the latter and larger category of "involved in the carrying on of any activity of rendering any service in relation to any trade, commerce or business". The expressions "any activity," "rendering any service" and "in relation to any trade, commerce or business" imply

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

charitable purpose. 16. What survives to be determined is whether any of BIS's activities fall within the latter and larger category of "involved in the carrying on of any activity of rendering any service in relation to any trade, commerce or business". The expressions "any activity," "rendering any service" and "in relation to any trade, commerce or business" imply

DCIT, UDUPI vs. M/S MANIPAL ACADEMY OF HIGHER EDUCATION, MANIPAL

In the result, the appeal of the revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Jason P Boaz

127 ITR 378.(A.P) 10. The learned AR than referred the recent decisions of the co- ordinate bench of this Tribunal dated 20-03-2015 in case of ACIT Vs City Hospital Charitable Trust, Bangalore in ITA No.676(B)/2014 and submitted that the Tribunal after considering the judgment of the Hon’ble Kerala High Court in case of Lissie

M/S SHRIMAD RAJCHANDRA GYAN MANDIR TRUST ,HUBLI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1), HUBLI

In the result, assessee’s appeal for Assessment

Bench: Shri Jason P. Boazassessment Year : 2011-12 M/S. Shrimad Rajchandra Gyan Vs. Assistant Commissioner Of Mandir Trust, Income-Tax, Beside Sbi, Zonal Office, Circle-3(1), Kusagal Road, Keswapur, Hubli. Hubballi – 580 023. Pan : Aacts 4573 L Appellant Respondent Assessee By : Smt. Sowmya, Advocate Revenue By : Shri. Sumer Singh Meena, Addl. Cit Date Of Hearing : 23.04.2019 Date Of Pronouncement : 03.05.2019 O R D E R

section 11(1)." 13. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the 13. In CIT v. Trustee of H.E.H. The Nizam's Supplemental Religious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted

ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, MANGALURU vs. M/S MANIPAL ACADEMY OF HIGHER EDUCATION, MANIPAL

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

Bench: Shri N.V. Vasudevan, Vice- & Shri Arun Kumar Garodiaassessment Year : 2013-14

section 11(1)." 13. In CIT v. Trustee of H.E.H. The Nizam's SupplementalReligious Endowment Trust (1981) 127 ITR 378, the Andhra Pradesh High Court has accepted the accounts maintained in respect of the trust in. conformity with the principles of accountancy for the purposes of determining the income derived from the property held in trust." 18. In view