SHRI SHRUTHIPARAMPARA GURUKULAM,BANGALORE vs. ITO, WARD-3, EXEMPTIONS, BANGALORE

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

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

charitable objects of the Trust. 14. Explanation 3 to section 80G states that "charitable purpose" does not include any purpose

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:

14 of the instrument of trust that the Muslims of the State and some other sections of the population had lagged behind in this particular branch of learning and it was to improve that situation that power was conferred on the trustees to grant financial assistance by way of ex gratia grants, etc., to scholars to enable them to prosecute

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

14,90,000/- Sub-Total\n115,40,37,713/- 30,01,23,000/- 145,41,60,713/- Total funds transferred from charitable trust, RECT to\n145,41,60,713/- trustees (Amount in Rs.)\n6.1.1 The assessee trust has furnished a detailed explanation to counter the above\nallegation. The Assessee Trust (RECT) vide its written submissions has admitted to\nthe factual

SRI CHANNAMALLIKARJUNA TRUST COMMITTEE,KOPPAL vs. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), BENGALURU

In the result, appeal of the Assessee is allowed

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sassessment Year : 2018-19 M/S. Sri Channamallikarjuna Trust Cit (Exemption), Vs. Committee Gangavathi Bengaluru. Sri Mallikarjuna Mutta – Gangavathi, District Koppal – 583 227. Pan : Aajts 7938 J Appellant Respondent

14 be charitable purpose. If the primary or predominant object of an institution is charitable, any other object which might not be charitable but which is ancillary or incidental to the dominant purpose, would not prevent the institution from being a valid charitable trust. The Court then held that the Section

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

14 of 37 provisions of section 12A(ab) which ought to have applied afresh for registration within 30 days of modification, which it failed to do so and hence it has violated the provisions of section 12A(ab) of the Act. ii. On the issue of loan obtained by trustees of the trust from banks and Finance Companies , which

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.

trust with reference to the construction of the expressions “charitable purpose” and “religious purpose.” 29.................................. 30.According to Section 2(15), the expression “charitable purpose” has been defined by way of an inclusive definition so as to include relief to the poor, education, medical relief and advancement of any other object of general public utility. A catena of decisions of this

M/S RABIYA BASARI BRAHAMATH-ULLAH ALLAYHA CHARITABLE TRUST vs. CIT,

In the result, the assessee's appeals are allowed

Bench: Smt. Asha Vijayaraghavan & Shri Jason P. Boaz

trust deed are charitable in nature as contemplated u/s 2(15) of the IT Act, and the objects of developing the Muslim Community, which is a broad cross section of general public itself in an object of advancement of general public utility, which is charitable object alongwith the other objects No.5,6,7,8,12,14

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

14 2022.\nHe further referred to another decision of Sri Srinivasa Educational\nand Charitable Trust v DCIT for AY 2021 22 in ITA No.\n835/Bang/2023 dated 24 March 2025 wherein paragraph No. 17.4 and\n17.5 it is further held that section

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’).

14 of 22 15. The ITAT Bangalore bench in M/s Sri Channamallikarjuna Trust Committee Gangavathi v CIT (E) – ITA No 1829/Bang/2018 (order dated 4.5.2022) explained the difference between charitable purpose and religious purpose and held as under:- “13. In sections

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

Trust Committee Gangavathi v CIT (E) – ITA No 1829/Bang/2018 (order dated 4.5.2022) explained the difference between charitable purpose and religious purpose and held as under:- “13. In sections 11, 12 & 13, a distinction has been drawn between 'charitable purpose' and 'religious purposes', but there is no definition of the term 'religious purpose' in the Act. Generally interpreted, it would encompass

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

Trust Committee Gangavathi v CIT (E) – ITA No 1829/Bang/2018 (order dated 4.5.2022) explained the difference between charitable purpose and religious purpose and held as under:- “13. In sections 11, 12 & 13, a distinction has been drawn between 'charitable purpose' and 'religious purposes', but there is no definition of the term 'religious purpose' in the Act. Generally interpreted, it would encompass

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

charitable Trust (60 taxrnamm.com 165). The relevant part of the order, is reproduced below: “14. We have considered hi submission. Section

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

charitable or religious trust which forfeits exemption by virtue of the provisions of the IT Act in regard to investment pattern or use of the trust property for the benefit of the settlor, etc., contained in section 13(1)(c) and (d) of that Act, the said rate will not apply: to the business profits of such trusts which

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

charitable or religious trust which forfeits exemption by virtue of the provisions of the IT Act in regard to investment pattern or use of the trust property for the benefit of the settlor, etc., contained in section 13(1)(c) and (d) of that Act, the said rate will not apply: to the business profits of such trusts which

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

14. For this, the Id. Counsel for the assessee has, again, cited the decision in the case of SNDP Yogam (supra). 15. We have heard the rival contentions of both the parties with reference to the merits of the additional ground. The relevant portion of Section 12A of the Act is as follows:- "Section 12A - (1) Conditions as to registration

M/S BANDANTHAMMA MATHU KALAMMA TRUST ,MYSORE vs. INCOME TAX OFFICER WARD-1(4), MYSORE

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

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

Charitable Trust". 13 ITA Nos.1761-1766/Bang/2018 M/s.Bandanthamma Mathu Kalamma Trust. [ii] It is submitted that the notice issued under section 148 of the Act being defective, the subsequent proceedings would not result in a valid assessment even if the assessee had filed the return. Reliance is placed on the parity of reasoning of the decision of the Hon'ble Calcutta High

M/S BANDANTHAMMA MATHU KALAMMA TRUST,MYSORE vs. INCOME TAX OFFICER WARD-1(4), MYSORE

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

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

Charitable Trust". 13 ITA Nos.1761-1766/Bang/2018 M/s.Bandanthamma Mathu Kalamma Trust. [ii] It is submitted that the notice issued under section 148 of the Act being defective, the subsequent proceedings would not result in a valid assessment even if the assessee had filed the return. Reliance is placed on the parity of reasoning of the decision of the Hon'ble Calcutta High

M/S BANDANTHAMMA MATHU KALAMMA TRUST ,MYSORE vs. INCOME TAX OFFICER WARD-1(4), MYSORE

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

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

Charitable Trust". 13 ITA Nos.1761-1766/Bang/2018 M/s.Bandanthamma Mathu Kalamma Trust. [ii] It is submitted that the notice issued under section 148 of the Act being defective, the subsequent proceedings would not result in a valid assessment even if the assessee had filed the return. Reliance is placed on the parity of reasoning of the decision of the Hon'ble Calcutta High