M/S. SRI BALAJI EDUCATIONAL AND CHARITABLE PUBLIC TRUST,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(4), CHENNAI

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

Charitable Public Trust S.No A.Y. Particulars Amount 1. 2013-14 Additional Income offered as per Final 22,54,41,000 2. 2014-15 Order dt. 14.06.2023 u/s.245D(4) of the 78,60,93,507 Act by IBS-2, New Delhi 3. 2015-16 98,44,35,413 4. 2016-17 47,00,04,866 5. 2017-18 Amount Disclosed

ACIT, CHENNAI vs. SRI BALAJI EDUCATIONAL AMD TRUST CHARITABLE PUBLIC TRUST , CHENNA

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

Charitable Public Trust S.No A.Y. Particulars Amount 1. 2013-14 Additional Income offered as per Final 22,54,41,000 2. 2014-15 Order dt. 14.06.2023 u/s.245D(4) of the 78,60,93,507 Act by IBS-2, New Delhi 3. 2015-16 98,44,35,413 4. 2016-17 47,00,04,866 5. 2017-18 Amount Disclosed

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

Charitable Trust, (2014) 267 CIT 305 (Del) (iii) Free Trade Union Multipurpose Project Trust vs. ITO, (2018) 95 Taxmann.Com 297 24. Per contra, ld. Authorised Representative strongly supporting the order of the ld. Commissioner of Income Tax (Appeals), in so far as it concerned the reliefs given by him, submitted at the outset that it was necessary

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

Charitable Trust, (2014) 267 CIT 305 (Del) (iii) Free Trade Union Multipurpose Project Trust vs. ITO, (2018) 95 Taxmann.Com 297 24. Per contra, ld. Authorised Representative strongly supporting the order of the ld. Commissioner of Income Tax (Appeals), in so far as it concerned the reliefs given by him, submitted at the outset that it was necessary

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

Charitable Trust, (2014) 267 CIT 305 (Del) (iii) Free Trade Union Multipurpose Project Trust vs. ITO, (2018) 95 Taxmann.Com 297 24. Per contra, ld. Authorised Representative strongly supporting the order of the ld. Commissioner of Income Tax (Appeals), in so far as it concerned the reliefs given by him, submitted at the outset that it was necessary

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

Charitable Trust, (2014) 267 CIT 305 (Del) (iii) Free Trade Union Multipurpose Project Trust vs. ITO, (2018) 95 Taxmann.Com 297 24. Per contra, ld. Authorised Representative strongly supporting the order of the ld. Commissioner of Income Tax (Appeals), in so far as it concerned the reliefs given by him, submitted at the outset that it was necessary

P.MADHURAJAN (INDL.),SALEM vs. ACIT, SALEM

In the result, the appeal of the assessee is partly allowed in ITA No

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita Nos. 584 & 585/Mds/2009 िनधा"रण वष" / Assessment Years : 2004-05 & 2005-06 Shri M. Govindarajan, The Asstt. Commissioner Of L/R Of Late Shri P. Madhurajan, V. Income Tax, No.3/20, Soundamman Koil Street, Central Circle, Elampillai - 637502 Salem. Pan: Airpm6868M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri R. Duraipandian, Sr. Ar सुनवाई क" तारीख/Date Of Hearing : 28.12.2016 घोषणा क" तारीख/Date Of Pronouncement : 22.02.2017 आदेश आदेश /O R D E R आदेश आदेश Per D.S. Sunder Singh:

Charitable Trust. The Income Tax department has examined Shri R. Vadivelu on 13.08.2004 by Asst. Director of Income Tax, Salem under Section 131 of the Act and Shri R. Vadivelu has given the statement stating that the school was functioning in 30 cents of land taken on lease for five years in November 2000. Out of the six trustees, four

P.MADHURAJAN (INDL.),SALEM vs. ACIT, SALEM

In the result, the appeal of the assessee is partly allowed in ITA No

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita Nos. 584 & 585/Mds/2009 िनधा"रण वष" / Assessment Years : 2004-05 & 2005-06 Shri M. Govindarajan, The Asstt. Commissioner Of L/R Of Late Shri P. Madhurajan, V. Income Tax, No.3/20, Soundamman Koil Street, Central Circle, Elampillai - 637502 Salem. Pan: Airpm6868M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri R. Duraipandian, Sr. Ar सुनवाई क" तारीख/Date Of Hearing : 28.12.2016 घोषणा क" तारीख/Date Of Pronouncement : 22.02.2017 आदेश आदेश /O R D E R आदेश आदेश Per D.S. Sunder Singh:

Charitable Trust. The Income Tax department has examined Shri R. Vadivelu on 13.08.2004 by Asst. Director of Income Tax, Salem under Section 131 of the Act and Shri R. Vadivelu has given the statement stating that the school was functioning in 30 cents of land taken on lease for five years in November 2000. Out of the six trustees, four

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, TRICHY vs. NEELARAJ VINOTH, PERAMBALUR

In the result, the appeal of the assessee is dismissed

Charitable and Educational Trust\nand its group on 15.02.2018. Offices of various entities connected\nwith the group as well as residence of key individuals were covered\nin the search including the residence of Mr.P.Neelraj, son in law of\nthe Chairman of the Trust. The assessee is a son of Mr.P.Neelraj. It\nis admitted fact that the assessee is a doctor

NEELARAJ VINOTH,PERAMBALUR vs. ACIT, CC-2, , TRICHY

In the result, the appeal of the revenue is dismissed and the CO filed by the assessee is dismissed

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1982/Chny/2024 & C.O.No. 60/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Assistant Commissioner Of Neelaraj Vinoth, Income Tax, V. 274-C, Thuraiyur Road, Central Circle -2, Perambalur – 621 212, Trichy. Tamilnadu. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (Respondent/Cross Objector) आयकर अपील सं./Ita No.: 2119/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Neelaraj Vinoth, Assistant Commissioner Of 274-C, Thuraiyur Road, V. Income Tax, Perambalur – 621 212, Central Circle -2, Tamilnadu. Trichy. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Charitable and Educational Trust and its group on 15.02.2018. Offices of various entities connected with the group as well as residence of key individuals were covered in the search including the residence of Mr.P.Neelraj, son in law of the Chairman of the Trust. The assessee is a son of Mr.P.Neelraj. It is admitted fact that the assessee is a doctor

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. S R TRUST, MADURAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1549/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Assistant Commissioner Of S R Trust, Income Tax, Vs. 1, Melur Road, Lake Area, Central Circle -1, Madurai – 625 107. Madurai. [Pan: Aacts-0376-F] (अपीलाथ"/Appellant) (""थ"/Respondent)

charitable objectives of the trust. In view of the foregoing, we are of the considered opinion that the assessee has adequately justified the expenditure as being incurred in furtherance of the trust’s objects. Consequently, the action of the ld.CIT(A) in allowing the assessee’s claim in respect of the travel expenses is found to be in accordance with

KATHIRAVAN SRINIVASAN ,PERAMBALUR vs. DCIT,CIRCLE-1, TIRUCHIRAPALLI

In the result, the appeal filed by the assessee in ITA No

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकरअपील सं./Ita Nos.: 170 & 171/Chny/2022 िनधा"रण वष" / Assessment Year: 2010-11 & आयकरअपील सं./Ita No.: 172/Chny/2022 िनधा"रण वष" / Assessment Year: 2011-12 Shri Kathiravan Srinivasan, Vs The Dcit, No.274C, Thuraiyur Road, Circle-1, 2Nd Perambalur – 621 212. Main Building, Floor, New No.44, Old No.4, Williams Road, Cantonment, Pan: Ajspk 6687Q Trichirapalli-620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri Darzakhum Songate, Cit सुनवाई क" तार"ख/Date Of Hearing : 18.10.2022 घोषणा क" तार"ख/Date Of Pronouncement : 23.12.2022 आदेश /O R D E R Per Mahavir Singh, Vp: These Three Appeals By The Assessee Are Arising Out Of Two Different Orders Of The Commissioner Of Income Tax (Appeals)-19, Chennai In Ita Nos.581 & 582/Chny/19-20 Dated 03.03.2022. The Assessments In Ita Nos.170 & 172/Chny/2022 Were Framed By The Jcit, Range 1, Trichy For The Assessment Years 2010-11 & 2011-12 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Orders Dated 31.03.2013 & 31.03.2014 Respectively. The Third Appeal In Ita No.171/Chny/2022 Is Against The Assessment Order Framed In Consequence To Revision Order Passed By Pcit U/S.263 Of The Act & Consequent Order Of The Ao For The Assessment Year 2010-11 U/S.143(3) R.W.S. 263 Of The Act Dated 12.03.2015 Passed By The Dcit, Circle-1, Trichy.

purchase of cow/ Buffalo and charge interest at the rate of 1% per month. The amount lent to the villagers was repaid during the year to a tune of Rs.94,00,000/-. The Inspector was deputed to enquire this also. On enquiry, the confirmation letters were not found genuine by the Inspector vide his report. Since the genuineness

KATHIRAVAN SRINIVASAN ,PERAMBALUR vs. DCIT ,CIRCLE-1, TIRUCHIRAPALLI

In the result, the appeal filed by the assessee in ITA No

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकरअपील सं./Ita Nos.: 170 & 171/Chny/2022 िनधा"रण वष" / Assessment Year: 2010-11 & आयकरअपील सं./Ita No.: 172/Chny/2022 िनधा"रण वष" / Assessment Year: 2011-12 Shri Kathiravan Srinivasan, Vs The Dcit, No.274C, Thuraiyur Road, Circle-1, 2Nd Perambalur – 621 212. Main Building, Floor, New No.44, Old No.4, Williams Road, Cantonment, Pan: Ajspk 6687Q Trichirapalli-620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri Darzakhum Songate, Cit सुनवाई क" तार"ख/Date Of Hearing : 18.10.2022 घोषणा क" तार"ख/Date Of Pronouncement : 23.12.2022 आदेश /O R D E R Per Mahavir Singh, Vp: These Three Appeals By The Assessee Are Arising Out Of Two Different Orders Of The Commissioner Of Income Tax (Appeals)-19, Chennai In Ita Nos.581 & 582/Chny/19-20 Dated 03.03.2022. The Assessments In Ita Nos.170 & 172/Chny/2022 Were Framed By The Jcit, Range 1, Trichy For The Assessment Years 2010-11 & 2011-12 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Orders Dated 31.03.2013 & 31.03.2014 Respectively. The Third Appeal In Ita No.171/Chny/2022 Is Against The Assessment Order Framed In Consequence To Revision Order Passed By Pcit U/S.263 Of The Act & Consequent Order Of The Ao For The Assessment Year 2010-11 U/S.143(3) R.W.S. 263 Of The Act Dated 12.03.2015 Passed By The Dcit, Circle-1, Trichy.

purchase of cow/ Buffalo and charge interest at the rate of 1% per month. The amount lent to the villagers was repaid during the year to a tune of Rs.94,00,000/-. The Inspector was deputed to enquire this also. On enquiry, the confirmation letters were not found genuine by the Inspector vide his report. Since the genuineness

KATHIRAVAN SRINIVASAN ,PERAMBALUR vs. DCIT,CIRCLE -1, TIRUCHIRAPALLI

In the result, the appeal filed by the assessee in ITA No

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकरअपील सं./Ita Nos.: 170 & 171/Chny/2022 िनधा"रण वष" / Assessment Year: 2010-11 & आयकरअपील सं./Ita No.: 172/Chny/2022 िनधा"रण वष" / Assessment Year: 2011-12 Shri Kathiravan Srinivasan, Vs The Dcit, No.274C, Thuraiyur Road, Circle-1, 2Nd Perambalur – 621 212. Main Building, Floor, New No.44, Old No.4, Williams Road, Cantonment, Pan: Ajspk 6687Q Trichirapalli-620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri Darzakhum Songate, Cit सुनवाई क" तार"ख/Date Of Hearing : 18.10.2022 घोषणा क" तार"ख/Date Of Pronouncement : 23.12.2022 आदेश /O R D E R Per Mahavir Singh, Vp: These Three Appeals By The Assessee Are Arising Out Of Two Different Orders Of The Commissioner Of Income Tax (Appeals)-19, Chennai In Ita Nos.581 & 582/Chny/19-20 Dated 03.03.2022. The Assessments In Ita Nos.170 & 172/Chny/2022 Were Framed By The Jcit, Range 1, Trichy For The Assessment Years 2010-11 & 2011-12 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Orders Dated 31.03.2013 & 31.03.2014 Respectively. The Third Appeal In Ita No.171/Chny/2022 Is Against The Assessment Order Framed In Consequence To Revision Order Passed By Pcit U/S.263 Of The Act & Consequent Order Of The Ao For The Assessment Year 2010-11 U/S.143(3) R.W.S. 263 Of The Act Dated 12.03.2015 Passed By The Dcit, Circle-1, Trichy.

purchase of cow/ Buffalo and charge interest at the rate of 1% per month. The amount lent to the villagers was repaid during the year to a tune of Rs.94,00,000/-. The Inspector was deputed to enquire this also. On enquiry, the confirmation letters were not found genuine by the Inspector vide his report. Since the genuineness

ACIT, CIRCLE-1, , MADURAI vs. DR.S. GURUSHANKAR,, MADURAI

Appeals stand dismissed whereas the assessee’s cross-objection stand allowed in terms of our order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

charitable entity having objects of Charity whereas MH was run on commercial basis. Pertinently, MH was a super specialty hospital having no competition. Therefore, to say that both the entities should have same profitability would not be a correct proposition. 8. It could also be seen that revenue’s appeals in case of M/s S.R. Trust (which is managing MMHRC

ACIT, CIRCLE-1, , MADURAI vs. DR.S. GURUSHANKAR,, MADURAI

Appeals stand dismissed whereas the assessee’s cross-objection stand allowed in terms of our order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

charitable entity having objects of Charity whereas MH was run on commercial basis. Pertinently, MH was a super specialty hospital having no competition. Therefore, to say that both the entities should have same profitability would not be a correct proposition. 8. It could also be seen that revenue’s appeals in case of M/s S.R. Trust (which is managing MMHRC

BANNARIAMMAN EDUCATIONAL TRUST,COIMBATORE vs. ACIT CENTRAL CIRCLE 3(2), CHENNAI

Trust Group, Tiruvannamalai through Mr. Yegappan. The Ld. \nAR pointed out that, even in this answer, he was not clear as to whom did \nthis single noting of Rs.11,99,000/- pertain to. The Ld. AR brought to our \nnotice that thereafter, a leading question (Q No. 34) was put forth by the \nInvestigating Officer to Shri Muthu, in which

BANNARIAMMAN EDUCATIONAL TRUST,COIMBATORE vs. ACIT CENTRAL CIRCLE 3(2), CHENNAI

Trust\n:: 58 ::\nShri Palanlappan directs me to do so. Shri Jai Shankar used to hand\nover cash to me and just say that the cash was from Bannari. I do not\nknow whether the cash belonged to Bannari Amman Sugars Pvt Ltd or\nBannari Amman Educational Trust.\nQ.No.12. In relation to M/s. Bannari Amman Sugars