THE CHRISTIA LITERATURE SOCIETY,CHENNAI vs. JCIT (OSD), CHENNAI

In the result, I set aside the orders of the lower authorities

Bench: Shri Abraham P. George]

section 11 of the Act. On the aspect of disallowance of depreciation also ld. CIT(A) upheld the view of the ld. Assessing Officer. According to him, Hon’ble Delhi High Court in the case of DIT (E) vs. Charanjiv Charitable Trust, (2014) 102

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]

section 10(23C)(vi) ... "... Though charity is a laudable object, that consideration is irrelevant under the said provision. What is relevant is purpose and administration of the institution only for education and nothing more or nothing less or anything else ... " Breach Candy Hospital Trust vs. Chief Commissioner (BOM) - 322 ITR 246 (BOM) 25. On a thorough reading of the judgments

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]

section 10(23C)(vi) ... "... Though charity is a laudable object, that consideration is irrelevant under the said provision. What is relevant is purpose and administration of the institution only for education and nothing more or nothing less or anything else ... " Breach Candy Hospital Trust vs. Chief Commissioner (BOM) - 322 ITR 246 (BOM) 25. On a thorough reading of the judgments

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]

section 10(23C)(vi) ... "... Though charity is a laudable object, that consideration is irrelevant under the said provision. What is relevant is purpose and administration of the institution only for education and nothing more or nothing less or anything else ... " Breach Candy Hospital Trust vs. Chief Commissioner (BOM) - 322 ITR 246 (BOM) 25. On a thorough reading of the judgments

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]

section 10(23C)(vi) ... "... Though charity is a laudable object, that consideration is irrelevant under the said provision. What is relevant is purpose and administration of the institution only for education and nothing more or nothing less or anything else ... " Breach Candy Hospital Trust vs. Chief Commissioner (BOM) - 322 ITR 246 (BOM) 25. On a thorough reading of the judgments

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

M/S VALLIAMMAL EDUCATIOANL TRUST,CHENNAI vs. DCIT (EXEMPTIONS),CHENNAI, CIRCLE, CHENNAI

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 411/Chny/2023 िनधा"रण वष" / Assessment Year: 2013-14 M/S. Valliammal Educational Office Of The Deputy Trust, V. Commissioner Of Income Tax F-40, 1St Main Road, Anna (Exemption), Nagar, Chennai – 600 102. Chennai Circle, Chennai. [Pan:Aaatv-1576-A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. T. Sandhyaarti, Ca & Ms. V. Yagnapriya, Ca ""यथ" क" ओर से/Respondent By : Mr. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.08.2023 घोषणा क" तारीख/Date Of Pronouncement : 23.08.2023

102. Chennai Circle, Chennai. [PAN:AAATV-1576-A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Ms. T. Sandhyaarti, CA & Ms. V. Yagnapriya, CA ""यथ" क" ओर से/Respondent by : Mr. D. Hema Bhupal, JCIT सुनवाई क" तारीख/Date of Hearing : 08.08.2023 घोषणा क" तारीख/Date of Pronouncement : 23.08.2023 आदेश /O R D E R PER MANJUNATHA

G2K TRUST,TRICHY vs. ITO, WARD-2(1), TRICHY

In the result, both the appeals filed by the assessee are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.3113 & 3114/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 & 2018-19 G2K Trust, Vs. The Income Tax Officer, No. 5, Abila Avenue, Santosh Garden, Ward 2(1), Kulumani Main Road, Woraiyur, Tiruchirappalli. Trichy 620 102. [Pan: Aactg4763G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. K. Abhirame, Advocate ""थ" की ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.02.2026 घोषणा की तारीख /Date Of Pronouncement : 24.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 04.07.2025 & 15.07.2025 Passed By The Addl/Jcit(A), Panaji For The Assessment Years 2017-18 & 2018-19 Respectively.

Charitable Trust (Supra) reads as under: “30. We may also refer to and rely upon a decision of the Delhi High Court in the case of G.V. Infosutions (P) Ltd. v. Dy: CIT [2019] 102 taxmann.com 397/261 Taxman 482. We may quote the relevant observations thus (page 170 of 13 ITR – OL): "8. The rejection of the petitioner's application

G2K TRUST,TRICHY vs. ITO, WARD-2(1), TRICHY

In the result, both the appeals filed by the assessee are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.3113 & 3114/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 & 2018-19 G2K Trust, Vs. The Income Tax Officer, No. 5, Abila Avenue, Santosh Garden, Ward 2(1), Kulumani Main Road, Woraiyur, Tiruchirappalli. Trichy 620 102. [Pan: Aactg4763G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. K. Abhirame, Advocate ""थ" की ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.02.2026 घोषणा की तारीख /Date Of Pronouncement : 24.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 04.07.2025 & 15.07.2025 Passed By The Addl/Jcit(A), Panaji For The Assessment Years 2017-18 & 2018-19 Respectively.

Charitable Trust (Supra) reads as under: “30. We may also refer to and rely upon a decision of the Delhi High Court in the case of G.V. Infosutions (P) Ltd. v. Dy: CIT [2019] 102 taxmann.com 397/261 Taxman 482. We may quote the relevant observations thus (page 170 of 13 ITR – OL): "8. The rejection of the petitioner's application

ARHATIC YOGA ASHRAM MANAGEMENT TRUST,CHENNAI vs. ITO (EXEMPTIONS) WARD 1, CHENNAI

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

Bench: Shri Justice P.P.Bhatt & Shri G.Manjunathai.T.A.No.2920/Chny/2017 ("नधा"रणवष" / Assessment Year: 2012-13) Arhatic Yoga Ashram Management Vs The Income Tax Officer Trust (Exemptions) Ward-1, 31/14, Krishnaswamy Avenue, Luz, Mylapore, Chennai-600 004. Chennai. Pan: Aabta 3404D (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 11(2) clearly mandates the assessee to specify purpose for accumulation of income, therefore, there is no reason to interfere with the findings recorded by the learned CIT(A) to deny accumulation of income u/s.11(2) of the Act. 7. We have heard the learned DR and perused the materials available on record. The assessee is a charitable trust

ANNAI GURUVAMMAL ALAGURAJ PUBLIC CHARITABLE TRUST,SANKARAPNDIAPURAM vs. ITO (EXEMPTION), MADURAI, MADURAI

The appeal of the assessee is allowed for statistical purposes

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

Charitable Trust Madurai. बनाम/ SF No.39/2, South Street, Vs. Sankarapandiapuram, Chatrapatti, Virudhunagar-626 102. "थायी लेखा सं./जीआइ आर सं./PAN/GIR No. AAHTA-9537-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ" की ओरसे/ Appellant by : Shri T. Vasudevan (Advocate)-Ld. AR ""थ" की ओरसे/Respondent by : Shri R. Clement Ramesh Kumar (CIT) – Ld. DR सुनवाई की तारीख/Date of Hearing

DIVYA RAO VASAN CHARITABLE FOUNDATION,CHENNAI vs. CIT (EXEMPTION), CHENNAI

In the result, these Writ Petitions are allowed on the following terms: - (i) The clause 5(ii) of Circular No

Bench: HON’BLE SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

Charitable Foundation, The Commissioner of Income I-72, 9th Street, Anna Nagar East, Vs. Tax, Chennai 600 102. Exemptions, Chennai PAN: AACTD 2326A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri. K. Balasubramanian, Advocate ""यथ" क" ओर से/Respondent by : Shri. V. Nandakumar, IRS, CIT. सुनवाई क" तारीख/Date of Hearing : 24.06.2024 घोषणा क" तारीख/Date

SRI PONNAIYAH RAMAJAYATHAMMAL EDUCTIONAL & CHARITABLE TRUST,CHENNAI vs. ACIT, TRICHY

Bench: Shri Chandra Poojari & Shri V. Durga Rao

charitable institution and also not accounted the transaction during the relevant financial year, the assessee could not substantiate the concealment of this sale transaction which is clearly establishes the default on his part and hence the lower authorities are justified in calculating the capital gains on account 'of sale of land and building at VOC Nagar, Thanjavur by applying

P.MURUGESAN,CHENNAI vs. ACIT, TRICHY

Bench: Shri Chandra Poojari & Shri V. Durga Rao

charitable institution and also not accounted the transaction during the relevant financial year, the assessee could not substantiate the concealment of this sale transaction which is clearly establishes the default on his part and hence the lower authorities are justified in calculating the capital gains on account 'of sale of land and building at VOC Nagar, Thanjavur by applying

ACIT, TRICHY vs. P.MURUGESAN, THANJAVUR

Bench: Shri Chandra Poojari & Shri V. Durga Rao

charitable institution and also not accounted the transaction during the relevant financial year, the assessee could not substantiate the concealment of this sale transaction which is clearly establishes the default on his part and hence the lower authorities are justified in calculating the capital gains on account 'of sale of land and building at VOC Nagar, Thanjavur by applying

ACIT, TRICHY vs. SHRI R.VISWANATHAN, DINDIGUL

Bench: Shri Chandra Poojari & Shri V. Durga Rao

charitable institution and also not accounted the transaction during the relevant financial year, the assessee could not substantiate the concealment of this sale transaction which is clearly establishes the default on his part and hence the lower authorities are justified in calculating the capital gains on account 'of sale of land and building at VOC Nagar, Thanjavur by applying

ACIT, TRICHY vs. SHRI P.JANAKAR, DINDIGUL

Bench: Shri Chandra Poojari & Shri V. Durga Rao

charitable institution and also not accounted the transaction during the relevant financial year, the assessee could not substantiate the concealment of this sale transaction which is clearly establishes the default on his part and hence the lower authorities are justified in calculating the capital gains on account 'of sale of land and building at VOC Nagar, Thanjavur by applying

CENTRE FOR URBANISATION BUILDINGS AND ENVIRONMENT (CUBE), ,CHENNAI vs. ITO, EXEMPTIONS WARD 4,, CHENNAI

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.3280/Chny/2024 िनधा9रण वष9 /Assessment Year: 2024-25

trust or institution and fulfillment of all the conditions laid down in clause 1 to 5 of section 80G. Accordingly, the approval u/s.80G of the Act was rejected and approval cancelled vide order dated 30/10/2024 by the Ld. CIT(E) in Application No.CIT (Exemption), Chennai/2024-25/12AA/12001 vide DIN & Notice No. ITBA /EXM/F /EXM45/2024-25/1070053179(1). 2. The Ld. Authorized Representative