JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

10. The ld.AR for the assessee submitted that the ld.CIT(A) has erred in confirming the action of the ld.AO in denial of exemption claimed u/s.11 of the Act on the ground of violation of provisions of section 13(1)(c) r.w.s.13(2) of the Act, without appreciating the fact that there is no violation of provision of section

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

10. The ld.AR for the assessee submitted that the ld.CIT(A) has erred in confirming the action of the ld.AO in denial of exemption claimed u/s.11 of the Act on the ground of violation of provisions of section 13(1)(c) r.w.s.13(2) of the Act, without appreciating the fact that there is no violation of provision of section

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

10. The ld.AR for the assessee submitted that the ld.CIT(A) has erred in confirming the action of the ld.AO in denial of exemption claimed u/s.11 of the Act on the ground of violation of provisions of section 13(1)(c) r.w.s.13(2) of the Act, without appreciating the fact that there is no violation of provision of section

M/S INNOVTIVE MICROFINANCE FOR POVERTY ALLEVIATION,CHENNAI vs. DCIT(EXEMPTIONS),CHENNAI CIRCLE, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Jagadish

section 2(15) of the Act and referred to various case laws. The ld.counsel for the assessee particularly referred to the decision of Bangalore Bench of this Tribunal in ITA Nos.172/Bang/2022 in the case of M/s. Navodaya Grama Vikas Charitable Trust, vide order dated 31.08.2023, wherein the Tribunal considering the entire factual aspect on identical facts allowed the claim

SATHYAM EDUCATIONAL & CHARITABLE TRUST ,TIRUPUR vs. ITO , NFAC , DELHI, -

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

Bench: Shri Mahavir Singh, Hon’Ble & Shriarun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.611 & 612/Chny/2022 िनधा"रणवष"/Assessment Years: 2014-15 & 2015-16 V. M/S. Sathyam Educational & The Income Tax Officer, Charitable Trust, Income Tax Department, No.233, Vijay Building, National Faceless Appeal Muthur Road, Centre (Nfac), Vellakovil, Delhi. Tirupur-638 111. [Pan:Aajts 4729 D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.Y.Sridhar, Fca ""थ" की ओर से /Respondent By : Mr.Hema Bhupal, Jcit सुनवाईकीतारीख/Date Of Hearing : 15.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

charitable activities during the year under consideration for construction of building therefore the same should not have been aggregated with the regular receipts while computing the annual receipt of the assessee for the purpose of claiming exemption u/s.10(23C)(iiiad) of the Act. The amount received by the assessee trust from its activities under the head School Fees/Other ITA Nos.611

SATHYAM EDUCATIONAL & CHARITABLE TRUST ,TIRUPUR vs. ITO , NFAC , DELHI, -

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

Bench: Shri Mahavir Singh, Hon’Ble & Shriarun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.611 & 612/Chny/2022 िनधा"रणवष"/Assessment Years: 2014-15 & 2015-16 V. M/S. Sathyam Educational & The Income Tax Officer, Charitable Trust, Income Tax Department, No.233, Vijay Building, National Faceless Appeal Muthur Road, Centre (Nfac), Vellakovil, Delhi. Tirupur-638 111. [Pan:Aajts 4729 D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.Y.Sridhar, Fca ""थ" की ओर से /Respondent By : Mr.Hema Bhupal, Jcit सुनवाईकीतारीख/Date Of Hearing : 15.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

charitable activities during the year under consideration for construction of building therefore the same should not have been aggregated with the regular receipts while computing the annual receipt of the assessee for the purpose of claiming exemption u/s.10(23C)(iiiad) of the Act. The amount received by the assessee trust from its activities under the head School Fees/Other ITA Nos.611

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]

10%. In any case, according to him, maximum marginal rate of tax, if applied could only be on such amount which came within purview of violation of Section 13(1) ( c) of ITA Nos2125 to 2128 :- 40 -: & 2219 to 2222 /2017 the Act and there cannot be a blanket denial of exemption under Section 11 of the Act. 38

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]

10%. In any case, according to him, maximum marginal rate of tax, if applied could only be on such amount which came within purview of violation of Section 13(1) ( c) of ITA Nos2125 to 2128 :- 40 -: & 2219 to 2222 /2017 the Act and there cannot be a blanket denial of exemption under Section 11 of the Act. 38

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]

10%. In any case, according to him, maximum marginal rate of tax, if applied could only be on such amount which came within purview of violation of Section 13(1) ( c) of ITA Nos2125 to 2128 :- 40 -: & 2219 to 2222 /2017 the Act and there cannot be a blanket denial of exemption under Section 11 of the Act. 38

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]

10%. In any case, according to him, maximum marginal rate of tax, if applied could only be on such amount which came within purview of violation of Section 13(1) ( c) of ITA Nos2125 to 2128 :- 40 -: & 2219 to 2222 /2017 the Act and there cannot be a blanket denial of exemption under Section 11 of the Act. 38

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

10 accumulation supporting charitable status is immaterial. She argued that the exemption under section 11 of the Act is assessed based on current year activities but not past or future intention as held by the Hon’ble Supreme Court in the case of Baba Banda Singh Bahadur Education Trust reported in [2023] 150 Taxmann.com

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

10 accumulation supporting charitable status is immaterial. She argued that the exemption under section 11 of the Act is assessed based on current year activities but not past or future intention as held by the Hon'ble Supreme Court in the case of Baba Banda Singh Bahadur Education Trust reported in [2023] 150 Taxmann.com

SAPPAHIRE EDUCATIONAL AND CHARITABLE TRUST,THANJAVUR vs. ITO, EXEMPTIONS WARD,, TRICHY

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Charitable Trust :: 10 :: of the Scheme is not applicable, then only clause 3(a) of the Scheme remains. What is covered in clause 3(a) of the Scheme is already provided in Section 144B(1) of the Act, which Section provides for faceless assessment, and covers assessment, reassessment or recomputation under Section 147 of the Act. Therefore, if Revenue

SUPPAHIRE EDUCATIONAL AND CHARITABLE TRUST,THANJAVUR vs. ITO, EXEMPTIONS WARD,, TRICHY

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Charitable Trust :: 10 :: of the Scheme is not applicable, then only clause 3(a) of the Scheme remains. What is covered in clause 3(a) of the Scheme is already provided in Section 144B(1) of the Act, which Section provides for faceless assessment, and covers assessment, reassessment or recomputation under Section 147 of the Act. Therefore, if Revenue

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

10-storeyed building known as “Sigappi Aachi building” over a period of five years from financial year 2006-07 to 2010-11. Subsequently, it was let out to corporate companies. According to the Ld. D.R., the Assessing Officer found that the assessee has invested surplus funds in construction of the building. The assessee has let out the building known

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

10-storeyed building known as “Sigappi Aachi building” over a period of five years from financial year 2006-07 to 2010-11. Subsequently, it was let out to corporate companies. According to the Ld. D.R., the Assessing Officer found that the assessee has invested surplus funds in construction of the building. The assessee has let out the building known

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

10-storeyed building known as “Sigappi Aachi building” over a period of five years from financial year 2006-07 to 2010-11. Subsequently, it was let out to corporate companies. According to the Ld. D.R., the Assessing Officer found that the assessee has invested surplus funds in construction of the building. The assessee has let out the building known

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

10-storeyed building known as “Sigappi Aachi building” over a period of five years from financial year 2006-07 to 2010-11. Subsequently, it was let out to corporate companies. According to the Ld. D.R., the Assessing Officer found that the assessee has invested surplus funds in construction of the building. The assessee has let out the building known