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

119(2)(b) of the Act for AY-2014-15. He argued vehemently that the primary object of the assessee has remained education from its inception and the main object never changed, the activity of selling of books and uniform specifically to the students of the DAV school trust only towards achievement of assessee’s main objects, being education

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

Charitable Institutions [2014] 51 taxmann.com 378/227 Taxman 369 (SC). In view of the clear provisions of the Act, and also the decision of the Hon’ble Supreme Court in the case, cited supra, it is clear that in case there is violation referred to under section 13(1)(c), then tax can be charged on such income which violates

M/S JAYA EDUCATIONAL TRUST,THIRUVALLUR vs. DCIT, CC1(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

Charitable Institutions [2014] 51 taxmann.com 378/227 Taxman 369 (SC). In view of the clear provisions of the Act, and also the decision of the Hon’ble Supreme Court in the case, cited supra, it is clear that in case there is violation referred to under section 13(1)(c), then tax can be charged on such income which violates

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

Charitable Institutions [2014] 51 taxmann.com 378/227 Taxman 369 (SC). In view of the clear provisions of the Act, and also the decision of the Hon’ble Supreme Court in the case, cited supra, it is clear that in case there is violation referred to under section 13(1)(c), then tax can be charged on such income which violates

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

Charitable Institutions [2014] 51 taxmann.com 378/227 Taxman 369 (SC). In view of the clear provisions of the Act, and also the decision of the Hon’ble Supreme Court in the case, cited supra, it is clear that in case there is violation referred to under section 13(1)(c), then tax can be charged on such income which violates

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

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

119(2)(b) of the Act for AY-2014-15. He\nargued vehemently that the primary object of the assessee has remained\neducation from its inception and the main object never changed, the\nactivity of selling of books and uniform specifically to the students of the\nDAV school trust only towards achievement of assessee's main objects,\nbeing education

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. However, after considering the submissions made by the assessee, the PCIT passed the order u/s 263 of the Act on the same day 31.03.2024 holding that the order passed by the Ld. AO is erroneous and prejudicial claim of exemption under section 11 of the Act. 3. Being aggrieved by the order of the ld. PCIT dated

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. However, after considering the submissions made by the assessee, the PCIT passed the order u/s 263 of the Act on the same day 31.03.2024 holding that the order passed by the Ld. AO is erroneous and prejudicial claim of exemption under section 11 of the Act. 3. Being aggrieved by the order of the ld. PCIT dated

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

2 CIT 1982 NEW TRUST 80G(5)(iv) CHARITABLE TRUST CASE & ITA 827/CHNY/2023 12A(1)(ac)(vi) 80G(5)(iii) 3 RAMAJAYAM NEW TRUST 80G(5)(iv) Earlier 12AA CHARITABLE TRUST CASE & rejected on ITA 1136/CHNY/2023 12A(1)(ac)(vi) 80G(5)(iii) 26.02.2020 by CIT(E), thus assessee is filing as new trust case. It was argued that these

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

119; or\n(d) the order has not been passed in accordance with any decision\nwhich is prejudicial to the assessee, rendered by the jurisdictional\nHigh Court or Supreme Court in the case of the assessee or any\nother person.] ***\n19. A bare reading of sub-Section (1) of Section 263 of the Act makes it\nabundantly clear that

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

2) of Section 151A of the Act, CBDT issued a notification dated 29th March, 2022 [Notification No.18/2022/F. No.370142/16/2022-TPL and formulated a Scheme. The Scheme provides that - (a) the assessment, reassessment or recomputation under Section 147 of the Act, (b) and the issuance of notice under Section 148 of the Act, shall be through automated allocation, in accordance with risk management

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

2) of Section 151A of the Act, CBDT issued a notification dated 29th March, 2022 [Notification No.18/2022/F. No.370142/16/2022-TPL and formulated a Scheme. The Scheme provides that - (a) the assessment, reassessment or recomputation under Section 147 of the Act, (b) and the issuance of notice under Section 148 of the Act, shall be through automated allocation, in accordance with risk management

VICTORIA EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-3,, CHENNAI

The appeal of the assessee is allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:946/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2022-23 Victoria Educational Trust, Ito, 62, 6Th Street, Vs. Exemptions Ward 3, S.R.P.Colony, Chennai. Peravallur, Chennai – 600 082. [Pan:Aabtv-0115-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate प्रत्यथी की ओर से/Respondent By : Shri. Kumar Chandan, J.C.I.T.

119(2)(b) of the Act was disposed of by the CIT(Exemptions), Chennai dated 11.01.2025 in DIN & Order No. ITBA/COM/F/17/2024-25/1072095396(1) by rejecting the plea for condonation of delay in filing the audit report in Form No. 10B for the reasons stated thereon. 11. The assessee in the pending first appeal against the intimation order dated had assailed

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 :

2. Representations received from stakeholders requesting for clarity on provisions related to trusts are dealt with as under: Clarification regarding application of section 115TD for failure to apply to registration/approval 3. Finance Act, 2023 has, inter-alia, amended section 115TD of the Act, so as to provide that the accreted income of the trusts not applying for registration/ approval, within

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 :

2. Representations received from stakeholders requesting for clarity on provisions related to trusts are dealt with as under: Clarification regarding application of section 115TD for failure to apply to registration/approval 3. Finance Act, 2023 has, inter-alia, amended section 115TD of the Act, so as to provide that the accreted income of the trusts not applying for registration/ approval, within

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].

2. Representations received from stakeholders requesting for clarity on provisions related to trusts are dealt with as under: Clarification regarding application of section 115TD for failure to apply to registration/approval 3. Finance Act, 2023 has, inter-alia, amended section 115TD of the Act, so as to provide that the accreted income of the trusts not applying for registration/ approval, within

CHARSUR ARTS FOUNDATION,CHENNAI vs. CIT, EXEMPTIONS,, CHENNAI

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

Bench: Shri George George Kand Shri Jagadishआयकर अपीलसं/.Ita No.:1753/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Charsur Arts Foundation, The Commissioner Of No. 72, M.C.P. Ramasamy Road, Vs. Income Tax (Exemption), Alwarpet, Chennai 600 018. Chennai. [Pan: Aabtc-1154-G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Hithesh, Advocate ""यथ" क" ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 28.08.2025 घोषणा क" तारीख/Date Of Pronouncement : 28.08.2025 आदेश/ O R D E R Per George George K: This Appeal Filed At The Instance Of The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Exemption), Chennai Dated 16.05.2025 Passed Under Section 119(2)(B) Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’) For The Assessment Year 2020-21. 2. The Solitary Issue Argued On Merits Is With Regard To Maintainability Of Appeal Filed Against The Order Passed Under Section 119(2)(B) Of The Act.

section 119(2)(b) of the Act vide his order dated 16.05.2025. 5. Being aggrieved, the assessee raised the following grounds of appeal: 1. The Id CIT E erred in rejecting the assessee application for condonation of delay in filing Form 10B and upholding the order of Id CPC. 2. That on the facts and circumstances the case

ST. JOSEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCOT. CENTRAL CIRCLE-1(3), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Charitable Trust enjoying registration w.e.f. 29.05.2012 u/s.12AA of the Act and pursuant to a search conducted in its premises on 07.11.2019, assessee- Trust agreed to treat the corpus donation of Rs.24 lakhs as voluntary contribution since it couldn’t furnish the confirmation letter from the donors and then filed the RoI for the searched AY 2020-21 on 05.01.2021 declaring