PUNJAB HERITAGE & TOURISM PROMOTION BOARD,CHANDIGARH vs. CIT EXEMPTIONS, CHANDIGARH

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.1126/Chandi/2024 Punjab Heritage & Tourism Promotion Board Cit (Exemptions) C/O Rajiv Goel & Associates बनाम/ Aaykar Bhawan. Sco 823-824,Sector 22-A Sector 17-E Vs. Chandigarh-160022. Chandigarh-160017 "ायीलेखासं./जीआइआरसं./Pan/Gir No.Aaatp-6562-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Dhruv Goel (Ca) -Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) (Virtual) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 17-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 07/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aggrieved By Cancellation Of Registrations U/S 12A As Well As U/S 12A(1)(Ac)(I) Vide Order Dated 04-11-2024 Of Ld. Commissioner Of Income Tax (Exemption), Chandigarh, [Cit(E)], The Assessee Is In Further Appeal Before Us With Following Grounds Of Appeal: - 1. That The Learned Cit(E) Has Erred In Law & On Facts In Initiating Proceedings For Cancellation Of Registration U/S 12A & Observing That Assessee Had Committed A Specified Violation As Defined In Section 12Ab(4)(Ii). 2. That The Learned Cit(E) Has Erred In Law & On Facts In Cancelling The Registration U/S 12A Of The Assessee As Per Provisions Of Section 12Ab(4)(Ii) Of The Act. 3. That The Learned C1T(E) Has Erred In Law & On Facts In Cancelling The Registration U/S 12A With Retrospective Effect From Ay 2010-11 Onwards.

losses of PTDC, state government decided to disinvest all assets of PTDC and there were 17 properties which could not be disinvested or leased out which include these fuel stations also. As per contractual terms with IOCL, these filling stations could not be transferred, encumbered or sold by PTDC. Accordingly, these fuel stations were transferred to the assessee and kept

DCIT, C-,1 (E), CHANDIGARH vs. M/S PUNJAB MEDICAL FOUNDATION CHARITABLE TRUST, JALANDHAR

In the result, appeal of the Revenue is dismissed

Bench: S/Shri N.K. Saini, Vice- & Rajpal Yadav, Vice-"नधा"रण वष"/ Asstt.Year: 2014-15 Dcit, Cir.1(Exemption) M/S.Punjab Medical Foundation Chandigarh. Vs. Charitable Trust 63-64, Waryam Nagar Cool Road, Jalandhar Pan : Aaatp 5171 B (Applicant) (Responent) : Shri Sudhir Sehal, Advocate Assessee By Revenue By : Shri Ashok K. Khana, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 18/11/2020 घोषणा क" तार"ख /Date Of Pronouncement: 21/12/2020 आदेश/O R D E R

carried out is concerned, the profit from medical store is incidental to the main object and not as separate business activity at the end of the assessee. The AO failed to appreciate this distinction which has been appreciated by the ld.CIT(A) while reversing the finding of the AO. It is also to be appreciated that in the last more

KANDI FRIENDS EDUCATIONAL TRUST,ROPAR vs. DEPUTY COMMISSION OF INCOME TAX, CL. 1, EXEMPTION, CHANDIGARH

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

carried out any Investigation in that area. The AO has not assigned any reason as to why he is departing from the principle of consistency where such honorarium has been allowed to these persons. Similarly Traveling Expenses has been allowed to the assessee in earlier years. The CIT (Appeals) failed to record any finding qua this aspect in right perspective

KANDI FRIENDS EDUCATIONAL TRUST,ROPAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, both the appeals are allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

carried out any Investigation in that area. The AO has not assigned any reason as to why he is departing from the principle of consistency where such honorarium has been allowed to these persons. Similarly Traveling Expenses has been allowed to the assessee in earlier years. The CIT (Appeals) failed to record any finding qua this aspect in right perspective

M/S MUKAND LAL COLLEGE SOCIETY,YAMUNANAGAR vs. ITO, YAMUNANAGAR

In the result, appeal of the assessee is allowed

losses was not allowed. 5. Being aggrieved the assessee carried the matter to the Ld. CIT(A) who also did not allow the set off by observing in para 5.10 and 5.11 of the impugned order as under: 5.10 The appellant has claimed carried forward of excess of expenditure over income

THE INSTITUTION OF CIVIL ENGINEERS SOCIETY,LUDHIANA vs. ACIT, EXEMPTIONS, C-1, CHANDIGARH

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

Forward were duly filled in ITR, the requirements of Section 11(2) gets complied. Also the provision of Filing Form-10 was in the form of attaching with return and there was no provisions in ITR-7 for attaching Balance sheet or any form. Further it was only after 31.03.2017 that the facility of filing Form 10 was opened even

HIMALAYAN BUDDHIST CULTURAL ASSOCIATION,KULLU vs. ACIT,CIRCLE/DCIT CPC,BENGLURU, MANDI

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

Bench: Due Date Of Filling Of Income Tax Return Was On Bonafide Grounds, The Cit(A) Has Erred In Not Condoning The Delay.

loss shall be computed after making the following adjustments, namely:— (i) any arithmetical error in the return; or (ii) an incorrect claim, if such incorrect claim is apparent from any information in the return; (b) .... There was neither any arithmetical error nor any incorrect claim which is apparent in the return of income filed u/s 139. The claim of amount

DCIT, C-1 (EXEMPTIONS), CHANDIGARH vs. THE INSTITUTION OF CIVIL ENGINEERS SOCIETY, LUDHIANA

In the result, appeal of the Revenue is dismissed

carrying them over to the table on the\nfirst page.\nThe Consultants will also prepare the award lists of the candidates, paper\nwise and course wise & roll number wise.\nThe Consultants will also check all cases of re checking of Test Booklets &\nOMR sheets and submit a report about the position of each Test Booklet &\nOMR sheet.\nThe Consultants will

M/S INFRASTRUCTURE DEVELOPMENT FUND,CHANDIGARH vs. ACIT (EXEMPTIONS), CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No. 644 & 645/Chd/2018 "नधा"रणवष" / Assessment Year: 2009-10 & 2014-15 Infrastructure Development Deputy Commissioner Of Income Tax बनाम Fund (Exemptions) Circle-2, Sco-71-17 Sector-17C Chandigarh Chandigarh "थायीलेखासं./Pan No: Aaal10136K अपीलाथ"/Appellant ""यथ"/Respondent आयकरअपीलसं./Ita No. 528 /Chd/2017 "नधा"रणवष" / Assessment Year: 2013-14 Infrastructure Development Acit, बनाम Fund Circle-2 (Exemptions), Sco-71-17 Sector-17C Chandigarh Chandigarh "थायीलेखासं./Pan No: Aaal10136K अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri A. K. Jindal, Ca, Smt. Ratan Kaur & Shri Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Shri Chandrajeet Singh, Cit(Dr) Smt. C. Chandrakanta, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 05.03.2020 उदघोषणा क" तार"ख/Date Of Pronouncement : 31/07/2020

carrying out provisions of the Act. The Section 24 is also proposed for amendment to add enabling provisions for notification of Rules for prescribing various procedures to be adopted for efficient administration of the Board. Hence this BILL66 * The Board thus, we hold, is not a mere nodal agency of the State. 16. The case laws relied

M/S INFRASTRUCTURE DEVELOPMENT FUND,CHANDIGARH vs. DCIT, (EXEMPTIONS), C-2, CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No. 644 & 645/Chd/2018 "नधा"रणवष" / Assessment Year: 2009-10 & 2014-15 Infrastructure Development Deputy Commissioner Of Income Tax बनाम Fund (Exemptions) Circle-2, Sco-71-17 Sector-17C Chandigarh Chandigarh "थायीलेखासं./Pan No: Aaal10136K अपीलाथ"/Appellant ""यथ"/Respondent आयकरअपीलसं./Ita No. 528 /Chd/2017 "नधा"रणवष" / Assessment Year: 2013-14 Infrastructure Development Acit, बनाम Fund Circle-2 (Exemptions), Sco-71-17 Sector-17C Chandigarh Chandigarh "थायीलेखासं./Pan No: Aaal10136K अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri A. K. Jindal, Ca, Smt. Ratan Kaur & Shri Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Shri Chandrajeet Singh, Cit(Dr) Smt. C. Chandrakanta, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 05.03.2020 उदघोषणा क" तार"ख/Date Of Pronouncement : 31/07/2020

carrying out provisions of the Act. The Section 24 is also proposed for amendment to add enabling provisions for notification of Rules for prescribing various procedures to be adopted for efficient administration of the Board. Hence this BILL66 * The Board thus, we hold, is not a mere nodal agency of the State. 16. The case laws relied

M/S INFRASTRUCTURE DEVELOPMENT FUND,CHANDIGARH vs. DCIT, (EXEMPTIONS), C-2, CHANDIGARH

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No. 644 & 645/Chd/2018 "नधा"रणवष" / Assessment Year: 2009-10 & 2014-15 Infrastructure Development Deputy Commissioner Of Income Tax बनाम Fund (Exemptions) Circle-2, Sco-71-17 Sector-17C Chandigarh Chandigarh "थायीलेखासं./Pan No: Aaal10136K अपीलाथ"/Appellant ""यथ"/Respondent आयकरअपीलसं./Ita No. 528 /Chd/2017 "नधा"रणवष" / Assessment Year: 2013-14 Infrastructure Development Acit, बनाम Fund Circle-2 (Exemptions), Sco-71-17 Sector-17C Chandigarh Chandigarh "थायीलेखासं./Pan No: Aaal10136K अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri A. K. Jindal, Ca, Smt. Ratan Kaur & Shri Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Shri Chandrajeet Singh, Cit(Dr) Smt. C. Chandrakanta, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 05.03.2020 उदघोषणा क" तार"ख/Date Of Pronouncement : 31/07/2020

carrying out provisions of the Act. The Section 24 is also proposed for amendment to add enabling provisions for notification of Rules for prescribing various procedures to be adopted for efficient administration of the Board. Hence this BILL66 * The Board thus, we hold, is not a mere nodal agency of the State. 16. The case laws relied

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

Charitable Trust 327 ITR 0073. 7. Now the department is in appeal. ITA 02/Chd/2020 & 7 Ors. M/s Manav Mangal Society Vs DCIT(E) 8. The ld. CIT-DR strongly supported the order passed by the A.O. and reiterated the observations made in the assessment order. It was further submitted that the payment of salary to the trustee / members

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

Charitable Trust 327 ITR 0073. 7. Now the department is in appeal. ITA 02/Chd/2020 & 7 Ors. M/s Manav Mangal Society Vs DCIT(E) 8. The ld. CIT-DR strongly supported the order passed by the A.O. and reiterated the observations made in the assessment order. It was further submitted that the payment of salary to the trustee / members

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

Charitable Trust 327 ITR 0073. 7. Now the department is in appeal. ITA 02/Chd/2020 & 7 Ors. M/s Manav Mangal Society Vs DCIT(E) 8. The ld. CIT-DR strongly supported the order passed by the A.O. and reiterated the observations made in the assessment order. It was further submitted that the payment of salary to the trustee / members

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

Charitable Trust 327 ITR 0073. 7. Now the department is in appeal. ITA 02/Chd/2020 & 7 Ors. M/s Manav Mangal Society Vs DCIT(E) 8. The ld. CIT-DR strongly supported the order passed by the A.O. and reiterated the observations made in the assessment order. It was further submitted that the payment of salary to the trustee / members

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

Charitable Trust 327 ITR 0073. 7. Now the department is in appeal. ITA 02/Chd/2020 & 7 Ors. M/s Manav Mangal Society Vs DCIT(E) 8. The ld. CIT-DR strongly supported the order passed by the A.O. and reiterated the observations made in the assessment order. It was further submitted that the payment of salary to the trustee / members

DCIT,CIRCLE-1(EXEMPTION), CHANDIGARH vs. M/S MANAV MANGAL SCHOOL( MANAV MANGAL SOCIETY), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

Charitable Trust 327 ITR 0073. 7. Now the department is in appeal. ITA 02/Chd/2020 & 7 Ors. M/s Manav Mangal Society Vs DCIT(E) 8. The ld. CIT-DR strongly supported the order passed by the A.O. and reiterated the observations made in the assessment order. It was further submitted that the payment of salary to the trustee / members

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

Charitable Trust 327 ITR 0073. 7. Now the department is in appeal. ITA 02/Chd/2020 & 7 Ors. M/s Manav Mangal Society Vs DCIT(E) 8. The ld. CIT-DR strongly supported the order passed by the A.O. and reiterated the observations made in the assessment order. It was further submitted that the payment of salary to the trustee / members

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

Charitable Trust 327 ITR 0073. 7. Now the department is in appeal. ITA 02/Chd/2020 & 7 Ors. M/s Manav Mangal Society Vs DCIT(E) 8. The ld. CIT-DR strongly supported the order passed by the A.O. and reiterated the observations made in the assessment order. It was further submitted that the payment of salary to the trustee / members