ACHARYA SRI TULSI MAHAPRAGYA SEVA KENDRA CHARITABLE TRUST ,BANGALORE vs. CIT(EXEMPTIONS), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3. The Petitioner further submits the Certificate of Registration of Dr. Santhosh Ram Gas Annexure 4, which duly evidences his qualifications and registration as a practicing medical professional specializing in Naturopathy services. 16. Further, the Petitioner submits that these services are available to everyone. A nominal fee is charged to cover the cost of consumables and doctor. The fee charged

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

3] Of the appeal LD. AR submitted that The Principal Commissioner of Income Tax lacks the jurisdiction to cancel the registration of the trust. He submitted that on 15/11/2022 the CIT (Exemption) Bangalore passed an order under section 127 of the Act pursuant to the survey under section 133A of the Act on 7 September 2022 wherein in order

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

Trust, ITA No.172/Bang/2022 Dated 31.8.2023. 2. Bharatha Swamukhi Samsthe (2009) 319 ITR (Trib) 0422 (Bang-Tribunal) 3. Disha India Micro Credit, ITA No.1374/Del/2010, Delhi dated 28.01.2011. 4. Bharat Integrated Social Welfare Agency, ITA No.115/CTK/2011 dated 27.05.2011. ITA Nos.744 & 745/Bang/2023 Sanghamitra Rural Financial Services, Bangalore Page 18 of 54 5. The ld. D.R. relied on the order of lower authorities

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

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

Trust, ITA No.172/Bang/2022 Dated 31.8.2023. 2. Bharatha Swamukhi Samsthe (2009) 319 ITR (Trib) 0422 (Bang-Tribunal) 3. Disha India Micro Credit, ITA No.1374/Del/2010, Delhi dated 28.01.2011. 4. Bharat Integrated Social Welfare Agency, ITA No.115/CTK/2011 dated 27.05.2011. 5. The ld. D.R. relied on the order of lower authorities and submitted that the assessee is charging exorbitant rate of interest

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

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. 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

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

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. 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

SOCIETY OF PERPETUAL HELP HOME FOR THE AGED,SASTHAN POST UDUPI vs. CIT (EXEMPTIONS), BANGALORE

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2025-26 Society Of Perpetual Help Home For The Aged, Vs. Cit(E), Pandeshwara Village, Bangalore. Sasthan Post, Udupi, Udupi – 576 226. Pan : Aabap 6Lo5 B Appellant Respondent Assessee By : Shri. Kashyap S. Vepari, Ca Revenue By : Shri. Murali Mohan, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 15.07.2025 Date Of Pronouncement : 31.07.2025

226. PAN : AABAP 6lO5 B APPELLANT RESPONDENT Assessee by : Shri. Kashyap S. Vepari, CA Revenue by : Shri. Murali Mohan, CIT(DR)(ITAT), Bangalore. Date of hearing : 15.07.2025 Date of Pronouncement : 31.07.2025 O R D E R Per Laxmi Prasad Sahu, Accountant Member : This is an appeal filed by the assessee against CIT(E)’s order vide DIN & Notice No: ITBA/EXM/F/EXM45/2024-

KARNATAKA HOUSING BOARD,BANGALORE vs. DDIT, BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Karnataka Housing The Additional Board, Director Of Income Iii Floor, Cauvery Bhavan, Tax (Exemptions), Kempegowda Road, Range – 17, Bangalore – 560009. Vs. Bangalore. Pan: Aaajk0398K Appellant Respondent & Assessment Year : 2010-11 M/S. Karnataka Housing The Additional Board, Director Of Income Iii Floor, Cauvery Bhavan, Tax (Exemptions), Kempegowda Road, Range – 17, Bangalore – 560009. Vs. Bangalore. Pan: Aaajk0398K Appellant Respondent

226,90,11,264 Interest income 14 4,98,34,617 Rent & lease rent 15 3,64,18,781 Other income from 16 9,24,72,950 schemes 244,77,37,612 Expenditure Financial charges 17 2,01,25,707 Cost of works sold (sales) 17A 204,59,06,033 Administration & other 18 15,67,71,939 expenses Depreciation

KARNATAKA HOUSING BOARD vs. ADDL.DIT,

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Karnataka Housing The Additional Board, Director Of Income Iii Floor, Cauvery Bhavan, Tax (Exemptions), Kempegowda Road, Range – 17, Bangalore – 560009. Vs. Bangalore. Pan: Aaajk0398K Appellant Respondent & Assessment Year : 2010-11 M/S. Karnataka Housing The Additional Board, Director Of Income Iii Floor, Cauvery Bhavan, Tax (Exemptions), Kempegowda Road, Range – 17, Bangalore – 560009. Vs. Bangalore. Pan: Aaajk0398K Appellant Respondent

226,90,11,264 Interest income 14 4,98,34,617 Rent & lease rent 15 3,64,18,781 Other income from 16 9,24,72,950 schemes 244,77,37,612 Expenditure Financial charges 17 2,01,25,707 Cost of works sold (sales) 17A 204,59,06,033 Administration & other 18 15,67,71,939 expenses Depreciation

M/S. SRI . ADICHUNCHANAGIRI SHILKSHANA TRUST,MANDYA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

3, he confirmed having been assessed to income-tax. Again, in reply to question No. 4, he explained that he used to purchase lubricating oil from different garages as well as through various brokers. Such lubricating oil was processed by him in his factory for sale. All payments were received by him through account payee cheques. In reply to question

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2(4), BENGALURU vs. SRI ADICHUNCHANAGIRI SHIKHANA TRUST, MANDYA

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

3, he confirmed having been assessed to income-tax. Again, in reply to question No. 4, he explained that he used to purchase lubricating oil from different garages as well as through various brokers. Such lubricating oil was processed by him in his factory for sale. All payments were received by him through account payee cheques. In reply to question

MARGDARSHAN FOUNDATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX (EXEMPTIONS), CIRCLE-1, BANGALORE

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

3. The Ld.AR submitted that assessee cannot be held to be religious trust as the activities carried out by the assessee is not in respect of any particular religion, community, caste, creed or any particular sect of people. He submitted that in fact for A.Y. 2022-23 the trust has carried out activities towards providing financial assistance, construction of houses

M/S. SARAKKI EDUCATIONAL SOCIETY,BANGALORE vs. INCOME TAX OFFICER, WARD-3(EXEMTIONS), BANGALORE

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

226 ITR 211 and the decision of the Hon’ble Andhra Pradesh High Court in the case of M/s. AWARE reported in 263 ITR 43 and held that for the purpose of section 13(1)(c) of the Act, the word “benefit” is not limited to advantage of pecuniary nature alone but extends to any intangible and indirect benefit also