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

losses by not being able to provide upgraded infrastructure to the students, considered vital for imparting quality education over subsequent years. However, the 'Trust shall, in future, again start utilizing the surplus funds for the objects of the Trust as soon as all litigations come to an end. Thus, in view of the above Court sanctions, it is requested that

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

losses by not being able to provide upgraded infrastructure to the students, considered vital for imparting quality education over subsequent years. However, the 'Trust shall, in future, again start utilizing the surplus funds for the objects of the Trust as soon as all litigations come to an end. Thus, in view of the above Court sanctions, it is requested that

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.

Trust for charitable purposes and the same being duly deposited as per provisions of section 11(5) of the Act, the addition made is against the scope of section 11 and is un-sustainable under law. 3. That the orders of the lower authorities are not justified on facts and the same are bad in law. 4. That the assessee

MAHARAWAL KHEWAJI TRUST,,FARIDKOT vs. DCIT, C-1 (E), CHANDIGARH

In the result, Assessee’s appeal is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 569/Chd/2019 "नधा"रण वष" / Assessment Year : 2015-16 Maharawal Khewaji Trust Dcit, C/O J K Gupta, ] बनाम Circle 1 Advocate, (Exemption), Vs. 4702, Hospital Bazar, Chandigarh. Bathinda. "थायी लेखा सं./Pan No: Aaatm2875R अपीलाथ"/Appellant ""यथ"/Respondent ( Virtual Hearing ) "नधा"रती क" ओर से/Assessee By : None राज"व क" ओर से/ Revenue By : Smt Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 14.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 06.08.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 15.02.2019 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

set off the loss in charitable hospital with other income of the current assessment year under appeal u/s 70/71 of the Income tax Act, 1961 as the assessee trust

M/S SHUBHAM COTTON MILLS PVT. LTD.,ELLENABAD vs. DCIT, CIRCLE, SIRSA

In the result appeal of the assessee is allowed

set-off the surrender with a view to avoid payment of taxes. When there was no loss either in past or in future, then the loss only shown during the post survey period is certainly doubtful as noted by the AO also. Under the facts and the circumstances of the case and in view of the discussion above, the action

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.

trust was to preserve various historical monuments and buildings in the state of Punjab to preserve the cultural heritage, the impugned activity has been carried out by the assessee out of compulsion due to circumstances arising since 1994. These fuel stations were set up by State Government to provide fuel support to the public at large during the troubled

SHRI ISHWAR HARI CHARITABLE TRUST,SNAGRUR vs. CIT EXEMPTIONS, CHANDIGARH

loss”.\n5. Ld. DR has relied upon the order of the Revenue\nAuthorities.\n6. In the light of the above, if we peruse the application\nfor condonation of delay, then it would reveal that due to\nsome clerical mistake, papers of this appeal have been put in\nthe folder of the second appeal which was duly filed well\nwithin limitation

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

loss claimed on account of this unit. 4.18 Further, I find that the issue of earning of profits by the charitable trust in the course of their activities has been considered in detail by the Hon'ble Punjab & Haryana High Court in the case of CT Educational Trust. It is found that profit rate declared by the appellant has been

SHRI ISHWAR HARI CHARITABLE TRUST,SANGRUR vs. CIT EXEMPTIONS, CHANDIGARH

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

loss”. ITA 719/CHD/2022 & ITA 475/CHD/2023 A.Y. 2022-23 6 5. Ld. DR has relied upon the order of the Revenue Authorities. 6. In the light of the above, if we peruse the application for condonation of delay, then it would reveal that due to some clerical mistake, papers of this appeal have been put in the folder of the second

M/S TEMPLE SHRIGOVERDHANNATHJI TRUST,KARNAL vs. CIT(E), CHANDIGARH

In the result, the appeal of the appellant trust stands allowed

Bench: Shri N.K. Saini & Shri Sanjay Gargआयकर अपील सं./ Ita No. 1463/Chd/2018 U/S 12Aa (1)(B)(Ii) Temple Shri Goverdhan Nath Ji The Cit (Exemptions), बनाम Trust, C R Building, D-562, Sheesh Mahal, Karnal Chandigarh Haryana 132001 "थायी लेखा सं./Pan No: Aasts3316F अपीलाथ"/Appellant ""यथ"/Respondent

loss', are required to be filed in Form No. ITR-7. Filing of return of income in Form No. ITR-5 clearly indicates that the applicant trust in its own perception as well deems itself to be out of the ambit of charitable activities. 11. In view of the above, it is held that the society's activities are limited

CT EDUCATIONAL SOCIETY,JALANDHAR vs. DCIT, CHANDIGARH

In the result, the appeal filed by the Assessee is Partly Allowed for\nStatistical Purposes as per the directions above

charitable trust imparting education.The copy of ITAT\nAmritsar Order for the AY 2006-07 is enclosed herewith in paper book. The copies\nof previous years assessment orders are also enclosed herewith in paper book\nreflecting no such disallowance being made in the previous years.\n6. That amount charged by the assessee society under multiple heads is not\nat all excessive

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

In the result, appeal of the Revenue is dismissed

Charitable or\nreligious trust - Denial of exemption (Sub-section (l)(c)) - Assessment year 2011-\nAssessee-society claimed exemption under section 11 - Assessing Officer\nconcluded that quantum jump in payment of salary to its executive director in\n assessment year under, appeal being unreasonable was in violation of section\n13(1)(c) and, therefore, he denied exemption under section 11 However

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

loss account. The AO further noted that though the assessee fund was registered as charitable entity for the impugned years ,yet it had failed to comply with the conditions prescribed u/s 11(2) regarding intimation of ITA No. 644 & 645/Chd/2018-& 528/2017 Infrastructure Development Fund, Chandigarh vs. DCIT, Chandigarh 3 income not utilized for charitable purposes during the year but accumulated

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

loss account. The AO further noted that though the assessee fund was registered as charitable entity for the impugned years ,yet it had failed to comply with the conditions prescribed u/s 11(2) regarding intimation of ITA No. 644 & 645/Chd/2018-& 528/2017 Infrastructure Development Fund, Chandigarh vs. DCIT, Chandigarh 3 income not utilized for charitable purposes during the year but accumulated

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

loss account. The AO further noted that though the assessee fund was registered as charitable entity for the impugned years ,yet it had failed to comply with the conditions prescribed u/s 11(2) regarding intimation of ITA No. 644 & 645/Chd/2018-& 528/2017 Infrastructure Development Fund, Chandigarh vs. DCIT, Chandigarh 3 income not utilized for charitable purposes during the year but accumulated

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

charitable or religious purposes in India during the previous year but is accumulated or set apart, either in whole or in part, for application to such purposes in India, such income so accumulated or set apart shall not be included in the total income of the previous year of the person in receipt of the income, provided the following conditions

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

setting up of infrastructure for imparting quality education. That befits them to be in the key roles assigned to them by the Society. To say that members of the society are earning commission income from Sushma Buildtech Ltd, Chandigarh, Mona Township Pvt.Ltd., New Delhi and GSC Estates Sector 22D, Chandigarh, it is observed that even if AO is convinced that

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

setting up of infrastructure for imparting quality education. That befits them to be in the key roles assigned to them by the Society. To say that members of the society are earning commission income from Sushma Buildtech Ltd, Chandigarh, Mona Township Pvt.Ltd., New Delhi and GSC Estates Sector 22D, Chandigarh, it is observed that even if AO is convinced that

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

setting up of infrastructure for imparting quality education. That befits them to be in the key roles assigned to them by the Society. To say that members of the society are earning commission income from Sushma Buildtech Ltd, Chandigarh, Mona Township Pvt.Ltd., New Delhi and GSC Estates Sector 22D, Chandigarh, it is observed that even if AO is convinced that