RURAL EDUCATION AND ACTION FOR LIBERATION,VILLUPURAM vs. ITO WARD 1, VILLUPURAM

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. No.1246/Chny/2019. "नधा$रण वष$ /Assessment Year : 2010-11

Trust u/s.11 of the Income Tax Act, 1961 (in short “the Act”). This issue is no longer res integra as it is settled by the Hon’bel Supreme Court in the case of CIT Vs. Rajasthan and Gujarati Charitable Foundation in [2018] 89 Taxmann.com 127(SC) as under: “so far as the issue regarding claim of depreciation u/s.32

SMT. LINGAMMAL RAMARAJU SHASTRA PRATHISHTA TRUST,RAJAPALAYAM vs. ACIT (EXEMPTIONS), COIMBATORE

sections 2(15), 11(4), and 13(1)(bb) (now not in the statute book), and then drew our attention to Paragraph 18 of the Thanthi Trust wherein it was held that a business whose income is utilized by the trust for the purpose of achieving its objective, is a business that is incidental to the attainment of objectives

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

M/S AVM CHARITIES,CHENNAI vs. ITO,EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

M/S. A V M CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

M/S AVM CHARITIES ,CHENNAI vs. ITO,EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

MEDICOS WELFARE TRUST,MADURAI vs. CIT, EXEMPTIONS,, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S. S. R. Raghunathaआयकर अपील सं./Ita No.: 1068/Chny/2025 धनिाारण वर्ा / Assessment Year: - Medicos Welfare Trust, The Commissioner Of Income Plot No. 127, E B Colony Vs. Tax (Exemption), Iyer Bunglow, Chennai. Ma Reserve Lines S.O, Alathur, Madurai – 625 014. [Pan: Aahtm-1007-C] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. P.M. Kathir, Advocate & Shri. G. Akash, Advocate प्रत्यथी की ओर से/Respondent By : Shri. Bipin C.N, Cit.

127, E B Colony vs. Tax (Exemption), Iyer Bunglow, Chennai. Ma Reserve Lines S.O, Alathur, Madurai – 625 014. [PAN: AAHTM-1007-C] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant by : Shri. P.M. Kathir, Advocate & Shri. G. Akash, Advocate प्रत्यथी की ओर से/Respondent by : Shri. Bipin C.N, CIT. सुनवाई की तारीख/Date of Hearing : 24.07.2025 घोर्णा की तारीख

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

DCIT, CEN CIR 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

127 taxmann.com 813 (Gujarat), the Hon'ble Gujarat High Court held that once debts were written off in books, it was to be allowed without expecting the assessee to prove that debts had actually become bad or they were recoverable or recovered in subsequent years. Head note of the decision is reproduced below: “Section 36(1)(vii) of the Income

DCIT, CC2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

127 taxmann.com 813 (Gujarat), the Hon'ble Gujarat High Court held that once debts were written off in books, it was to be allowed without expecting the assessee to prove that debts had actually become bad or they were recoverable or recovered in subsequent years. Head note of the decision is reproduced below: “Section 36(1)(vii) of the Income

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 (where the assessee's father Shri Neelraj is the Chairman) and M/s DS group - Rs.35,00,000 and Rs.30,00,000 respectively, adding up to Rs.65,00,000, which was amount transferred to Vinoth. Few more such instances are given below: Sl Who transferred Amount Source No funds to vinoth transferred 1 K MURALIDHARAN 6000000 RECEIVED

KATHIRAVAN SRINIVASAN ,PERAMBALUR vs. DCIT,CIRCLE -1, TIRUCHIRAPALLI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकरअपील सं./Ita Nos.: 170 & 171/Chny/2022 िनधा"रण वष" / Assessment Year: 2010-11 & आयकरअपील सं./Ita No.: 172/Chny/2022 िनधा"रण वष" / Assessment Year: 2011-12 Shri Kathiravan Srinivasan, Vs The Dcit, No.274C, Thuraiyur Road, Circle-1, 2Nd Perambalur – 621 212. Main Building, Floor, New No.44, Old No.4, Williams Road, Cantonment, Pan: Ajspk 6687Q Trichirapalli-620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri Darzakhum Songate, Cit सुनवाई क" तार"ख/Date Of Hearing : 18.10.2022 घोषणा क" तार"ख/Date Of Pronouncement : 23.12.2022 आदेश /O R D E R Per Mahavir Singh, Vp: These Three Appeals By The Assessee Are Arising Out Of Two Different Orders Of The Commissioner Of Income Tax (Appeals)-19, Chennai In Ita Nos.581 & 582/Chny/19-20 Dated 03.03.2022. The Assessments In Ita Nos.170 & 172/Chny/2022 Were Framed By The Jcit, Range 1, Trichy For The Assessment Years 2010-11 & 2011-12 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Orders Dated 31.03.2013 & 31.03.2014 Respectively. The Third Appeal In Ita No.171/Chny/2022 Is Against The Assessment Order Framed In Consequence To Revision Order Passed By Pcit U/S.263 Of The Act & Consequent Order Of The Ao For The Assessment Year 2010-11 U/S.143(3) R.W.S. 263 Of The Act Dated 12.03.2015 Passed By The Dcit, Circle-1, Trichy.

127/- (which has been admitted by the appellant as unexplained) as per the order dated 12.3.2015 u/s 143(3) rws 263 of the Act are sustained. Similarly for assessment year 2011-12, the CIT(A) confirmed the addition by observing in para 5.8 to 5.10 as under:- 5.8 While going through the details submitted by the appellant

KATHIRAVAN SRINIVASAN ,PERAMBALUR vs. DCIT,CIRCLE-1, TIRUCHIRAPALLI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकरअपील सं./Ita Nos.: 170 & 171/Chny/2022 िनधा"रण वष" / Assessment Year: 2010-11 & आयकरअपील सं./Ita No.: 172/Chny/2022 िनधा"रण वष" / Assessment Year: 2011-12 Shri Kathiravan Srinivasan, Vs The Dcit, No.274C, Thuraiyur Road, Circle-1, 2Nd Perambalur – 621 212. Main Building, Floor, New No.44, Old No.4, Williams Road, Cantonment, Pan: Ajspk 6687Q Trichirapalli-620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri Darzakhum Songate, Cit सुनवाई क" तार"ख/Date Of Hearing : 18.10.2022 घोषणा क" तार"ख/Date Of Pronouncement : 23.12.2022 आदेश /O R D E R Per Mahavir Singh, Vp: These Three Appeals By The Assessee Are Arising Out Of Two Different Orders Of The Commissioner Of Income Tax (Appeals)-19, Chennai In Ita Nos.581 & 582/Chny/19-20 Dated 03.03.2022. The Assessments In Ita Nos.170 & 172/Chny/2022 Were Framed By The Jcit, Range 1, Trichy For The Assessment Years 2010-11 & 2011-12 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Orders Dated 31.03.2013 & 31.03.2014 Respectively. The Third Appeal In Ita No.171/Chny/2022 Is Against The Assessment Order Framed In Consequence To Revision Order Passed By Pcit U/S.263 Of The Act & Consequent Order Of The Ao For The Assessment Year 2010-11 U/S.143(3) R.W.S. 263 Of The Act Dated 12.03.2015 Passed By The Dcit, Circle-1, Trichy.

127/- (which has been admitted by the appellant as unexplained) as per the order dated 12.3.2015 u/s 143(3) rws 263 of the Act are sustained. Similarly for assessment year 2011-12, the CIT(A) confirmed the addition by observing in para 5.8 to 5.10 as under:- 5.8 While going through the details submitted by the appellant

KATHIRAVAN SRINIVASAN ,PERAMBALUR vs. DCIT ,CIRCLE-1, TIRUCHIRAPALLI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकरअपील सं./Ita Nos.: 170 & 171/Chny/2022 िनधा"रण वष" / Assessment Year: 2010-11 & आयकरअपील सं./Ita No.: 172/Chny/2022 िनधा"रण वष" / Assessment Year: 2011-12 Shri Kathiravan Srinivasan, Vs The Dcit, No.274C, Thuraiyur Road, Circle-1, 2Nd Perambalur – 621 212. Main Building, Floor, New No.44, Old No.4, Williams Road, Cantonment, Pan: Ajspk 6687Q Trichirapalli-620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri Darzakhum Songate, Cit सुनवाई क" तार"ख/Date Of Hearing : 18.10.2022 घोषणा क" तार"ख/Date Of Pronouncement : 23.12.2022 आदेश /O R D E R Per Mahavir Singh, Vp: These Three Appeals By The Assessee Are Arising Out Of Two Different Orders Of The Commissioner Of Income Tax (Appeals)-19, Chennai In Ita Nos.581 & 582/Chny/19-20 Dated 03.03.2022. The Assessments In Ita Nos.170 & 172/Chny/2022 Were Framed By The Jcit, Range 1, Trichy For The Assessment Years 2010-11 & 2011-12 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Orders Dated 31.03.2013 & 31.03.2014 Respectively. The Third Appeal In Ita No.171/Chny/2022 Is Against The Assessment Order Framed In Consequence To Revision Order Passed By Pcit U/S.263 Of The Act & Consequent Order Of The Ao For The Assessment Year 2010-11 U/S.143(3) R.W.S. 263 Of The Act Dated 12.03.2015 Passed By The Dcit, Circle-1, Trichy.

127/- (which has been admitted by the appellant as unexplained) as per the order dated 12.3.2015 u/s 143(3) rws 263 of the Act are sustained. Similarly for assessment year 2011-12, the CIT(A) confirmed the addition by observing in para 5.8 to 5.10 as under:- 5.8 While going through the details submitted by the appellant