MADURAI AGRI BUSINESS INCUBATION FORUM ,COIMBATORE vs. CIT(EXEMPTIONS), CHENNAI

In the result, all the appeals filed by the assessees are allowed for statistical purposes

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

10, clause (ac) of sub-section (1) of section 12A of the Act, inserting section 12AB of the Act and amending the first and second proviso to sub-section (5) of section 80G of the Act. 7.4 We are concerned with the provisions of section 80G of the Act in these cases. In view of the above provisions, the deduction

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

46) after 01.04.2011 does not preclude a statutory corporation, board, or whatever such body may be called, from claiming that it is set up for a charitable purpose and seeking exemption under Section 10(23C) or other provisions of the Act. C. Statutory regulators C.1. The income and receipts of statutory regulatory bodies which are for instance, tasked with exclusive

ALAMELU MEMORIAL CHARITABLE TRUST,THIRUVALLUR vs. CIT, EXEMPTIONS,, CHENNAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.814/Chny/2025 Alamelu Memorial Charitable Trust, Vs. The Commissioner Of Income Tax No. 46, 2Nd Street, Sp Munusamy [Exemptions], Nagar, Gnt Road, Thervazhi, Chennai. Gummidipoondi, Thiruvallur 601 201. [Pan:Aaita6393E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Vishva Padmanabhan, C.A. ""थ" की ओर से/Respondent By : Shri G. Nandha Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 04.06.2025 घोषणा की तारीख /Date Of Pronouncement : 30.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.03.2024 Passed By The Ld. Commissioner Of Income Tax (Exemption), Chennai In Rejecting The Application Filed In Form 10Ab Under Clause (Iii) Of First Proviso To Section 80G(5) Of The Income Tax Act, 1961 [“Act” In Short].

10, clause (ac) of sub-section (1) of section 12A of the Act, inserting section 12AB of the Act and amending the first and second proviso to sub-section (5) of section 80G of the Act. 7.4 We are concerned with the provisions of section 80G of the Act in these cases. In view of the above provisions, the deduction

THE THANTHI TRUST,CHENNAI vs. JCIT, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

46. The argument of Mr.V.S.Jayakumar, is that the decision in Loka Shikshana Trust (supra) was rendered by a Three Judge Bench of the Hon’ble Supreme Court. As per the observation of Hon’ble Mr.Justice M.H.Beg, as could be seen from paragraph 32 of the judgment, it has been observed that although the term ‘education’, as used in Section

THE THANTHI TRUST,CHENNAI vs. JCIT, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

46. The argument of Mr.V.S.Jayakumar, is that the decision in Loka Shikshana Trust (supra) was rendered by a Three Judge Bench of the Hon’ble Supreme Court. As per the observation of Hon’ble Mr.Justice M.H.Beg, as could be seen from paragraph 32 of the judgment, it has been observed that although the term ‘education’, as used in Section

THE THANTHI TRUST,CHENNAI vs. JCIT, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

46. The argument of Mr.V.S.Jayakumar, is that the decision in Loka Shikshana Trust (supra) was rendered by a Three Judge Bench of the Hon’ble Supreme Court. As per the observation of Hon’ble Mr.Justice M.H.Beg, as could be seen from paragraph 32 of the judgment, it has been observed that although the term ‘education’, as used in Section

THE THANTHI TRUST,CHENNAI vs. ADIT (EXEMPTIONS) , CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

46. The argument of Mr.V.S.Jayakumar, is that the decision in Loka Shikshana Trust (supra) was rendered by a Three Judge Bench of the Hon’ble Supreme Court. As per the observation of Hon’ble Mr.Justice M.H.Beg, as could be seen from paragraph 32 of the judgment, it has been observed that although the term ‘education’, as used in Section

PROTECT AND RESCUE ANIMALS IN NEED INITIATIVE (PRANI),CHENNAI vs. CIT, EXEMPTIONS,, CHENNAI

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

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1151/Chny/2025 Assessment Years: - Protect & Rescue Animals In Need Commissioner Of Income Tax Initiative (Prani), (Exemptions), No.10, Door No.5, Bnb Flats, Chennai. 6Th Avenue, Ashok Nagar, Chennai- 600 083. [Pan: Aaftp0832N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri M.Viswanathan, C.A. प्रत्यर्थी की ओर से /Revenue By : Shri Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 08.07.2025 घोषणा की तारीख /Date Of Pronouncement : 03.10.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

10, clause (ac) of sub-section (1) of Page - 11 - of 22 section 12A of the Act, inserting section 12AB of the Act and amending the first and second proviso to sub-section (5) of section 80G of the Act. 7.4 We are concerned with the provisions of section 80G of the Act in these cases. In view

SOCIETY FOR COMMUNITY ORGANISATION AND PEOPLES EDUCATION (SCOPE),TIRUCHIRAPPALLI vs. CIT, EXEMPTIONS,, CHENNAI

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

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1127/Chny/2025 Assessment Years: - Society For Community Organization Commissioner Of Income Tax & Peoples Education (Scope), (Exemptions), No.17, 16Th Cross, Ahmed Colony, Chennai. Ramalinga Nagar, Tiruchirappalli, Tamil Nadu- 620 003. [Pan: Aaets3488C] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri N.Arjun Raj, Advocate, प्रत्यर्थी की ओर से /Revenue By : Shri Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 07.07.2025 घोषणा की तारीख /Date Of Pronouncement : 03.10.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

10, clause (ac) of sub-section (1) of section 12A of the Act, inserting section 12AB of the Act and amending the first and second proviso to sub-section (5) of section 80G of the Act. 7.4 We are concerned with the provisions of section 80G of the Act in these cases. In view of the above provisions, the deduction

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

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

charitable trust. Viz-a-viz decision of Co- ordinate Bench in the case of Pentofour Software Employees Welfare Foundation (supra), ld. Commissioner of Income Tax (Appeals) observed that the assessee there was formed as a company under Section 25 of the Companies Act, 1956 and not comparable to a private discretionary trust. Nevertheless, he agreed with the contention

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

charitable trust. Viz-a-viz decision of Co- ordinate Bench in the case of Pentofour Software Employees Welfare Foundation (supra), ld. Commissioner of Income Tax (Appeals) observed that the assessee there was formed as a company under Section 25 of the Companies Act, 1956 and not comparable to a private discretionary trust. Nevertheless, he agreed with the contention

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

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]

46 ITR (Trib) 80. (ii) DIT (Exemption) vs Charanjiv 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

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]

46 ITR (Trib) 80. (ii) DIT (Exemption) vs Charanjiv 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

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]

46 ITR (Trib) 80. (ii) DIT (Exemption) vs Charanjiv 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

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]

46 ITR (Trib) 80. (ii) DIT (Exemption) vs Charanjiv 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

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. The Id. Counsel for the assessee further argued that the PCIT ought to have applied his mind before passing the order directing the AO to deny exemption u/s 11 of the Act on the entire receipts when the appellant has already paid the taxes on cash receipts u/s 115BBC of the Act and holds valid registration u/s 12AA