ST.JOSEPH'S INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

CHARITABLE TRUST was already stayed by the Supreme Court prior to issue of notice dated 04.03.2024 u/s 263 of the Act itself; V. The Hon'ble Apex Court in the case of Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association, Madras, (1992) 3 SCC 1 has explained the meaning of ‘quashing of an order’ and ‘stay

ST.JOSEPH'S EDUCATIONAL TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

CHARITABLE TRUST was already stayed by the Supreme Court prior to issue of notice dated 04.03.2024 u/s 263 of the Act itself; V. The Hon'ble Apex Court in the case of Shree Chamundi Mopeds Ltd. Vs. Church of South India Trust Association, Madras, (1992) 3 SCC 1 has explained the meaning of ‘quashing of an order’ and ‘stay

ST.JOSEPH'S INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Charitable Trust\nwas not at all in existence.\nX. Hence, we find no reason to hold that the search assessment order dated\n28.09.2021 u/s 153A r.w. section 144 of the Act is erroneous insofar as\nprejudicial to the interest of revenue on this very jurisdictional issue. Hence,\nwe quash the revision order passed by PCIT dated 31.03.2024 and allow this

PRATHYUSHA EDUCATIONAL TRUST,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri George Mathan & Shri Inturi Rama Rao

search and seizure action by the Revenue, which resulted in unearthing of evidences, inter alia, that the assessee collected huge amount of Rs.1,57,42,700/- from students, in cash, without issuing any receipts and without entering them in the regular books of accounts maintained by the trust. When the assessee, a public charitable

PRATHYUSHA EDUCATIONAL TRUST,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri George Mathan & Shri Inturi Rama Rao

search and seizure action by the Revenue, which resulted in unearthing of evidences, inter alia, that the assessee collected huge amount of Rs.1,57,42,700/- from students, in cash, without issuing any receipts and without entering them in the regular books of accounts maintained by the trust. When the assessee, a public charitable

SRINIVASAN CHARITABLE AND EDUCATIONAL TRUST,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-2, , TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

Charitable & Educational Trust :: 5 :: allowed in this case was two months and this fact is recorded by Hon'ble High Court in para 25 & 26 as under- 25. On the question of adherence to the principles of natural justice. the relevant sequence of dates and events is that a notice under Section 153C was issued on 25.10.2019 in regard

SRINIVASAN CHARITABLE AND EDUCATIONAL TRUST,PERAMBALUR vs. ACIT, CENTRAL COIRCLE-2, , TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

Charitable & Educational Trust :: 5 :: allowed in this case was two months and this fact is recorded by Hon'ble High Court in para 25 & 26 as under- 25. On the question of adherence to the principles of natural justice. the relevant sequence of dates and events is that a notice under Section 153C was issued on 25.10.2019 in regard

SRINIVASAN CHRITABLE AND EDUCATIONAL TRUST, ,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-2, TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

Charitable & Educational Trust :: 5 :: allowed in this case was two months and this fact is recorded by Hon'ble High Court in para 25 & 26 as under- 25. On the question of adherence to the principles of natural justice. the relevant sequence of dates and events is that a notice under Section 153C was issued on 25.10.2019 in regard

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, TRICHY, TRICHY vs. SRINIVASAN CHARITABLE AND EDUCATIONAL TRUST, PERAMBALUR

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

Charitable & Educational Trust :: 5 :: allowed in this case was two months and this fact is recorded by Hon'ble High Court in para 25 & 26 as under- 25. On the question of adherence to the principles of natural justice. the relevant sequence of dates and events is that a notice under Section 153C was issued on 25.10.2019 in regard

SRINIVASAN CHARITABLE AND EDUCATION TRUST,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-2, TRICHY, TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

Charitable & Educational Trust :: 5 :: allowed in this case was two months and this fact is recorded by Hon'ble High Court in para 25 & 26 as under- 25. On the question of adherence to the principles of natural justice. the relevant sequence of dates and events is that a notice under Section 153C was issued on 25.10.2019 in regard

SRINIVASAN CHARITABLE AND EDUCATION TRUST,PERAMBALUR vs. ACIT, CENTRAL CIRLCE-2, , TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

Charitable & Educational Trust :: 5 :: allowed in this case was two months and this fact is recorded by Hon'ble High Court in para 25 & 26 as under- 25. On the question of adherence to the principles of natural justice. the relevant sequence of dates and events is that a notice under Section 153C was issued on 25.10.2019 in regard

SRINIVASAN CHARITABLE AND EDUCATION TRUST,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-2, TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

Charitable & Educational Trust :: 5 :: allowed in this case was two months and this fact is recorded by Hon'ble High Court in para 25 & 26 as under- 25. On the question of adherence to the principles of natural justice. the relevant sequence of dates and events is that a notice under Section 153C was issued on 25.10.2019 in regard

N. VIJAY KUMAR, ACIT, CHENNAI vs. RAJAH MUTHIAH CHETTIAR CHARITABLE AND EDUCATIONAL TRUST, CHENNAI

In the result, appeals filed by the Revenue & CO of assessee are

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Charitable & Educational Trust :: 6 :: Enterprises Pvt. Ltd. in ITA Nos.1166 & 1167/Chny/2023 dated 06.06.2024, and it was held, as under: - 12. We have heard both the parties, perused the materials available on record and gone through orders of the authorities below. The AO levied penalty u/s.270A of the Act, for both the assessment years on the ground that the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SUBRAMANIAM KATHIRESAN, CHENNAI

In the result, appeal filed by the Revenue for AY 2014-15 is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

Charitable Trust); and then the AO of the searched person should examine the seized material and should be able to satisfy himself that the segregated seized assets belong to the third party (in this case that of the assessee) or books/documents/information, pertains or relates to the third party (in this case the assessee who was not covered by the search

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 Trust engaged in providing education through the educational institutions run under its aegis in the streams of Medicine, Engineering, Arts, Science and Allied Disciplines. :-3-: ITA. No.:1249 &1471/Chny/2025 3. An action u/s.132 of the Act was undertaken in the case of an assessee on 24.06.2016 and the residential and office premises of the Chairman and Managing Trustee M.K.Rajagopalan

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 Trust engaged in providing education through the educational institutions run under its aegis in the streams of Medicine, Engineering, Arts, Science and Allied Disciplines. :-3-: ITA. No.:1249 &1471/Chny/2025 3. An action u/s.132 of the Act was undertaken in the case of an assessee on 24.06.2016 and the residential and office premises of the Chairman and Managing Trustee M.K.Rajagopalan

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

SRINIVASAN CHARITABLE AND EDUCATIONAL TRUST,PERAMBALUR vs. ACIT,CENTRAL CIRCLE-2, TRICHY

In the result, appeals filed by the assessee and appeal filed by the\nRevenue are allowed for statistical purposes

Charitable & Educational Trust] wherein the Tribunal\nappreciated that AO failed to give proper opportunity to assessee before\nframing assessment orders, restored the matter back to the file of the AO\nfor de-novo assessment by relying on the decision of Hon'ble Madras High\nCourt in the case of B.Kubendran vs. DCIT [2021] 126 taxmann.com 107\n(Madras) by holding