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

disallowance of the exemption claimed under section n of the Act, on the ground that the activities of the appellant are hit by the proviso to section 2(15) of the Act on the facts and circumstances of the case. ITA Nos.744 & 745/Bang/2023 Sanghamitra Rural Financial Services, Bangalore Page 2 of 54 4. The authorities below failed to appreciate that

THE ROTARY CHARITABLE TRUST MALAVALLI,MANDYA vs. ITO, EXEMPTIONS, WARD-1, MYSORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17 The Rotary Charitable Trust Malavalli Thyagaraj Road Kotemalvalli Malavalli Ito Vs. Mandya 571 430 Exemption Ward Karnataka Bengaluru Pan No : Aactt2807N Appellant Respondent Appellant By : Sri Tharun Kothari, A.R. Respondent By : Sri Subramanian, D.R. Date Of Hearing : 15.05.2025 Date Of Pronouncement : 28.07.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Addl/Jcit(A) Kochi Dated 20.01.2025 Vide Din & Order No. Itba/Apl/S/250/2024-25/1072336484(1) Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”) For The Assessment Year 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal: The Rotary Charitable Trust, Malavalli Page 2 Of 11 The Rotary Charitable Trust, Malavalli Page 3 Of 11

Charitable Trust, Malavalli Page 6 of 11 6. Being aggrieved by the aforesaid intimation u/s 143(1) of the Act dated 29/12/2023 passed by the CPC, Bengaluru, the assessee preferred an appeal before the ld. CIT(A)/ ld. Addl/JCIT(A). 7. The ld. Addl/JCIT(A) Kochi dismissed the appeal of the assessee on the ground that the assessee had failed

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

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

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

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

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

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

In the result, appeals of the assessee are dismissed

disallowance of the\nexemption claimed under section n of the Act, on the ground that the activities\nof the appellant are hit by the proviso to section 2(15) of the Act on the facts\nand circumstances of the case.\n4. The authorities below failed to appreciate that the activities of the appellant fell\nunder \"relief to poor\" and thus

M/S. NAVODAYA GRAMA VIKAS CHARITABLE TRUST,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, BANGALORE

In the result, the appeal filed by assessee stands allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18 M/S. Navodaya Grama Vikas Charitable Trust, The Deputy #14-7-1005, Scdcc Commissioner Of Bank Ltd., Income Tax, Head Office Building, Central Circle – 1, Kodialbail, Vs. Mangaluru. Mangaluru – 575 003. Pan: Aaatn7594E Appellant Respondent : Shri V. Srinivasan, Advocate & Assessee By Ms. Sunaina Bhatia, Ca Revenue By : Shri D.K. Mishra, Cit Dr Date Of Hearing : 07-07-2023 Date Of Pronouncement : 31-08-2023 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 07.03.2022 Passed By Ld.Cit(A)-2, Panaji For A.Y. 2017-18 On Following Grounds Of Appeal: “1. The Orders Of The Authorities Below In So Far As They Are Against The Appellant Are Opposed To Law. Equity, Weight Of Evidence. Probabilities, Facts & Circumstances Of The Case. 2. The Learned Cit [A] Is Not Justified In Upholding The Disallowance Of The Exemption Claimed U/S.11 Of The Act

Charitable Trust, The Deputy #14-7-1005, SCDCC Commissioner of Bank Ltd., Income Tax, Head Office Building, Central Circle – 1, Kodialbail, Vs. Mangaluru. Mangaluru – 575 003. PAN: AAATN7594E APPELLANT RESPONDENT : Shri V. Srinivasan, Advocate & Assessee by Ms. Sunaina Bhatia, CA Revenue by : Shri D.K. Mishra, CIT DR Date of Hearing : 07-07-2023 Date of Pronouncement : 31-08-2023 ORDER

KK FOUNDATION AND PUBLIC CHARITABLE TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, (EXEMPTION) CIRCLE-1 , BENGALURU

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

Charitable Trust, Bangalore Page 5 of 6 the CPC system finds if -any adjustment to the total income is to be made as per the rules, the proposed changes are sent to the appellant by email and 30 days' time is given to the appellant to respond. If the Assessee responds, the response is duly considered. In the instant case

ASSISTANT COMMISSIONER OF INCOME TAX, BENGALURU vs. NAGARJUNA EDUCATION SCOEITY, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

charitable objectives. During the assessment year 2016-17, the trust repaid ₹2 crores of the said loan and claimed it as an application of income, relying on CBDT Circular No. 100 dated 24/01/1973. 11.1 The AO disallowed

M/S SINDHI YOUTH ASSOCIATION,BANGALORE vs. ASSISTANT DIRECTOR OF INCOME TAX (EXEMPTIONS), CIRCLE-17(2), BANGALORE

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2008-09

disallowed by the AO. 6. On appeal in the first round, the CIT(Appeals) observed that the as per provisions of sections 11 to 13, there is no scope for computing any loss from property held under trust wholly for charitable

RAJIV VENKATPATHI GOWDA,BENGALURU vs. DCIT, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2015-16

Charitable Trust and therefore treated the said credits as unexplained investments u/s. 69 of the Act. Similarly, the AO had disallowed

RAGIGUDDA SRI PRASANNA ANJANEYA SWAMY BHAKTA MANDALI TRUST,BANGALORE vs. INCOME TAX OFFICER, WARD-2. (EXEMPTION), BANGALORE

In the result, appeals of the assessee for both the years are partly allowed for statistical purposes

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

charitable trust / institution is to be computed by applying commercial principle apart from sections 11, 12 and 13 of the Act. He noted that the provisions of sections 70 to 80 is applicable only in respect of assessee's other than those and are covered under sections 11, 12 and 13 and 10(23)(c) of the Act because

RAGIGUDDA SRI PRASANNA ANJANEYA SWAMY BHAKTA MANDALI TRUST,BANGALORE vs. INCOME TAX OFFICER, WARD-2. (EXEMPTION) , BANGALORE

In the result, appeals of the assessee for both the years are partly allowed for statistical purposes

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

charitable trust / institution is to be computed by applying commercial principle apart from sections 11, 12 and 13 of the Act. He noted that the provisions of sections 70 to 80 is applicable only in respect of assessee's other than those and are covered under sections 11, 12 and 13 and 10(23)(c) of the Act because

M/S. KSRTC PASSENGERS ACCIDENT RELIEF FUND TRUST,BANGALORE vs. INCOME TAX OFFICER (EXEMPTIONS), WARD-1, BENGALURU

In the result, appeals filed by the assessee for both the years under consideration stands allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

trust and thus disallowed the claim. 3.4 The Ld.AO noted that assessee sold capital asset for Rs.21,95,401/- and the same was not included in the receipt side of the I&E account. The Ld.AO opined that as the entire amount Page 4 of 18 ITA Nos. 373 & 374/Bang/2023 of acquisition was exempted in the year of acquisition

M/S. KSRTC PASSENGERS ACCIDENT RELIEF FUND TRUST,BANGALORE vs. INCOME TAX OFFICER (EXEMPTIONS), WARD-1, BENGALURU

In the result, appeals filed by the assessee for both the years under consideration stands allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

trust and thus disallowed the claim. 3.4 The Ld.AO noted that assessee sold capital asset for Rs.21,95,401/- and the same was not included in the receipt side of the I&E account. The Ld.AO opined that as the entire amount Page 4 of 18 ITA Nos. 373 & 374/Bang/2023 of acquisition was exempted in the year of acquisition

SHREE SUBRAHMANYA TEMPLE ,THOKUR vs. ITO, EXEMPTIONS, WARD-2, MANGALORE

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

Bench: Shri Waseem Ahmedassessment Year: 2016-17

charitable trust that earned receipts of . Page 8 of 10 ₹45,20,536/- during the relevant year. Against this, it applied ₹33,13,891/- as revenue expenditure, ₹45,875/- as capital expenditure, and set aside ₹10,88,080/- as a bank deposit. The AO disallowed

INCOME TAX OFFICER, EXEMPTIONS, WARD-3, BENGALURU vs. SARAKKI EDUCATION SOCIETY, BENGALURU

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

disallowance is taxable under maximum marginal rate. ITA Nos.1973, 1974, 1991 & 1992/Bang/2024 M/s. Sarakki Educational Society, Bangalore Page 3 of 19 3. The revenue has raised following grounds of appeal in ITA No.1991/Bang/2024 for the AY 2017-18:- 4. Brief facts of the case are that the assessee society is a charitable trust