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’).

5)(iii), benefit of deduction under section 80G can be claimed. Thus, it could be said that a public religious trust, not meant for the benefit of a particular community, caste or section, will be entitled to claim exemption on its income in the same way as a public charitable

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

5)(iii), benefit of deduction under section 80G can be claimed. Thus, it could be said that a public religious trust, not meant for the benefit of a particular community, caste or section, will be entitled to claim exemption on its income in the same way as a public charitable

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

5)(iii), benefit of deduction under section 80G can be claimed. Thus, it could be said that a public religious trust, not meant for the benefit of a particular community, caste or section, will be entitled to claim exemption on its income in the same way as a public charitable

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

section 80G. S. 80G (5) provides that the trust should be established for a “charitable purpose”. Explanation 3 to s. 80G provides that “charitable purpose” does not include a purpose which is of a “religious nature”. S. 80G(5)(iii

ANUGRAHA EDUCATION TRUST,SULLIA vs. COMMISSIONER OF INCOME TAX(EXEMPTIONS), BANGALORE

In the result, appeal filed by the assessee is allowed

iii) of first proviso to sub-section (5) of\nsection 80G of the Act in Form No.10AB on 29.6.2024 vide Ack.no.\n534264060290624.\n3.1 The ld. CIT(Exemptions), Bangalore after granting opportunity\nof being heard rejected the approval u/s 80G of the Act on the\nground that provisions of section 80G of the Act are applicable in\nthe cases of receipts

KANCHI PERIYAVA TRUST-MYSORE ,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX(EXEMPTIONS), , BENGALURU

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

iii) to first proviso to section 80G(5) cannot be excluded and or it has not been theintention of the CBDT while issuing the circular. There cannot be a distinction within the same provisionwithout bringing out any exception and even this provision is for the benefit of the donors who aredonating money to the charitable trusts

KANCHI PERIYAVA TRUST-MYSORE,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX(EXEMPTIONS), BENGALAURU

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

iii) to first proviso to section 80G(5) cannot be excluded and or it has not been theintention of the CBDT while issuing the circular. There cannot be a distinction within the same provisionwithout bringing out any exception and even this provision is for the benefit of the donors who aredonating money to the charitable trusts

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

In the result, appeal of the assessee is partly allowed for\nstatistical purposes

iii) of first proviso to sub-section (5) of\nsection 80G of the Act.\n7.1 On receipt of application in form 10AB dated 13.8.2024 for\napproval u/s 80G (5) of the Act, the assessee was granted\nopportunity vide notice dated 30.11.2024. The ld. CIT(Exemption)\nrejected the approval u/s 80G of the Act mainly for the reason that\nthe

SHRI PURUSHOTTAMA NARASIMHA BHARATI SANATANA SABHA,UTTARA KANNADA vs. INCOME-TAX OFFICER, EXEMPTIONS, WARD-1, HUBLI

In the result, the appeal filed by the assessee trust is allowed

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year : 2024-25

section 80G. S. 80G (5) provides that the trust should be established for a “charitable purpose”. Explanation 3 to s. 80G provides that “charitable purpose” does not include a purpose which is of a “religious nature”. S. 80G(5)(iii

CITY HOSPITAL CHARITABLE TRUST ,MANGALORE vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, BANGALORE

In the result, appeal filed by the assessee is allowed

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

Charitable Trust, Mangalore Page 4 of 10 proviso to sub-section (5) of section 80G from 07.04.2022 to assessment year 2024-25 in Form No.10AC by the ld. PCIT/CIT. The assessee trust thereafter applied for permanent approval as per clause (iii

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

80G of the Act. The assessee trust is engaged in charitable activities, including education and healthcare. The Assessing Officer (AO) disallowed the donation made by the assessee to another trust on the ground that the recipient trust was not registered under section 12A of the Act. As per the provisions of section 11 of the Act, a charitable trust

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

80G of the Act. The assessee trust is engaged in charitable activities, including education and healthcare. The Assessing Officer (AO) disallowed the donation made by the assessee to another trust on the ground that the recipient trust was not registered under section 12A of the Act. As per the provisions of section 11 of the Act, a charitable trust

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

iii) of first proviso to subsection (5) of section 80G. We also noticed that the CIT(E) has treated the application as one filed under sub-clause (B) of clause (iv) of first proviso to subsection (5) of section 80G and accordingly rejected Subharma Charitable Trust

M/S. SRINIVAS INSTITUTE OF MEDICAL SCIENCE AND RESEARCH CENTRE,MANGALROE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BENGALURU

In the result, the appeal filed by the assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: N.A.

charitable purpose under section 2(15) of the Act. In this regard, the CIT(A) has rightly observed that the conclusions of the AO are without any material and that the receipt of capitation fees has not been established nor were there any proceedings against the assessee under the Karnataka Educational Institutions (Prohibition of Capitation Fees

DHWANI SHRISTI FOUNDATION ,BAGANALORE vs. COMMISSIONER OF INCOME TAX(EXEMPTIONS) , BANGALORE

In the result, appeal filed by the assessee in ITA

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

80G of the Act. 2. First, we take up ITA No.2463/Bang/2024 for adjudication. In this appeal, the assessee has raised the following grounds of appeal: ITA Nos.2463 & 2464/Bang/2024 Dhwani Shristi Foundation Designation: Charitable Trust, Bangalore Page 2 of 12 ITA Nos.2463 & 2464/Bang/2024 Dhwani Shristi Foundation Designation: Charitable Trust, Bangalore Page 3 of 12 3. The assessee is registered

DHWANI SHRISTI FOUNDATION,BANGALORE vs. COMMISSIONER OF INCOME TAX(EXEMPTIONS, BENGALURU

In the result, appeal filed by the assessee in ITA

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

80G of the Act. 2. First, we take up ITA No.2463/Bang/2024 for adjudication. In this appeal, the assessee has raised the following grounds of appeal: ITA Nos.2463 & 2464/Bang/2024 Dhwani Shristi Foundation Designation: Charitable Trust, Bangalore Page 2 of 12 ITA Nos.2463 & 2464/Bang/2024 Dhwani Shristi Foundation Designation: Charitable Trust, Bangalore Page 3 of 12 3. The assessee is registered

ACADEMY OF GENERAL EDUCATION,UDUPI vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, BANGALORE

In the result, appeal filed by the assessee is allowed

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

iii) of first proviso to sub-section (5) of section 80G of the Act in Form No.10AB on 10.08.2024. 3.1 The ld. CIT(Exemptions), Bangalore after granting opportunity of being heard rejected the approval u/s 80G of the Act on the following grounds: (i) The assessee trust reported surplus every year which is not utilized towards charitable

ACADEMY OF LIBERAL EDUCATION REGD ,SULLIA vs. COMMISSIONER OF INCOME TAX, EXEMPTIONS, BENGALURU

In the result, appeal filed by the assessee is allowed

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

iii) of first proviso to sub-section (5) of section 80G of the Act in Form No.10AB on 08.08.2024. 3.1 The ld. CIT(Exemptions), Bangalore after granting opportunity of being heard rejected the approval u/s 80G of the Act on the following grounds: (i) The assessee trust reported surplus every year which is not utilized towards charitable