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

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. The impugned notice dated 27th August, 2022 has been issued by respondent ITA Nos.2416 & 2417/Chny/2024 (AY 2018-19) Sappahire Educational & Charitable Trust

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

Charitable Trust (supra), we hold the activity of sale of uniforms, textbooks, etc. and the excess of income over expenditure arising thereon which are disclosed in Form-10A are incidental to the attainment of objects of the assessee. Therefore, the assessee is entitled to the benefit of section 11 of the Act for the year under consideration, accordingly, we hold

LOGANATHAN DHANDAPANI,CHENNAI vs. ACIT, NCC-3(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

MANICKAM CHETTIAR VELMURUGAN,CHENNAI vs. ITO, NCC-19(1), CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 25.07.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

MANICKAM CHETTIAR VELMURUGAN,CHENNAI vs. ITO, NCC-19(1), CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 25.07.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

THANARAJ SUMATHI,MAYILADUTHURAI vs. ITO, WARD-1,, KUMBAKONAM

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2031/Chny/2025 यनिाारणवर्ा / Assessment Year:2019-20 Thanaraj Sumathi, Income Tax Officer, No.3/25, North Street, Vs. Ward-1 Moovalur, Kumbakonam. Mayiladuthurai – 609806. Tamil Nadu. [Pan:Knyps-1061-J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Cit. सुनवाईकीतारीख/Date Of Hearing : 13.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

CHAHIDA BEGAM,PUDUCHERRY vs. INCOME TAX OFFICER, WARD 3, PUDUCHERRY RANGE, INCOME TAX OFFICE, PUDUCHERRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 29.03.2023 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

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

Charitable Trust (supra), we hold the\nactivity of sale of uniforms, textbooks, etc. and the excess of income over\nexpenditure arising thereon which are disclosed in Form-10A are\nincidental to the attainment of objects of the assessee. Therefore, the\nassessee is entitled to the benefit of section 11 of the Act for the year\nunder consideration, accordingly, we hold

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

Charitable Trust (supra), we hold the\nactivity of sale of uniforms, textbooks, etc. and the excess of income over\nexpenditure arising thereon which are disclosed in Form-10A are\nincidental to the attainment of objects of the assessee. Therefore, the\nassessee is entitled to the benefit of section 11 of the Act for the year\nunder consideration, accordingly, we hold

JAYARAMAN RUDRASEKAR,VELLORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 144B of the Jayaraman Rudrasekar :: 3 :: Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 07.04.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles

MAC CHARITIES,CHENNAI vs. COMMISSIONER OF INCOME TAX (APPEALS), NEW DELHI

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

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.2950/Chny/2024 िनधा9रण वष9 /Assessment Year: 2020-21 Mac Charities, The Income Tax Officer, Mac Ich Building, Vhs Campus, Vs. Dlc-Ca-(201)(1), Ttti Post, Tharamani, Chennai. Chennai – 600 113. [Pan: Aaatm 0483F]

144B of the Income-tax Act,1961 (hereinafter “the Act”) on 24.09.2022. MAC Charities :- 2 -: 2. There is a delay of 386 days in filing the appeal by the assessee. The assessee has filed condonation petition/affidavit stating the reasons for delay in filing the appeal. We have considered the petition/affidavit of delay in filing the appeal and satisfied that there

NILAA CHARITABLE TRUST,VILLUPURAM vs. ITO, EXEMPTIONS WARD-1, CHENNAI

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

Bench: SHRI GEORGE GEORGE K (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)

Charitable Trust, Income Tax Officer T.Kosapalayam Village, Vs. (Exemption), Anniyur Post, Gingee Road, Ward-1, Villupuram Dist- 605 202. Chennai. PAN: AABTN-0861-F (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Mr. Sendamarai Kannan, Advocate ""यथ" क" ओर से/Respondent by : Ms. Gouthami Manivasagam, JCIT सुनवाई क" तारीख/Date of Hearing : 25.02.2025 घोषणा क" तारीख/Date

SRI VENKATESWARA ORPHANAGE KADUVELI,THANJAVUR vs. ITO, EXEMPTION WARD,, TRICHY

In the result, the appeal of the assessee is partly allowed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

section 144B of the Income Tax Act, 1961 (hereinafter referred to as the “Act”), pertaining to Assessment Year (A.Y.) 2020-21. :-2-: ITA. No:1679/Chny/2025 2. The brief facts of the case as seen from the records are as follows. The assessee is a public charitable trust

ANNAI KANTHAMMAL RAMACHANDRAN EDUCATIONAL AND CHARITABLE TRUST,KRISHNAGIRI vs. ITO, EXEMPTIONS WARD,, SALEM

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri S.R. Raghunatha

Charitable Trust, vs. Exemptions Ward, 1/136, Hosur Main Road, Salem. Rayakottai, Krishnagiri – 635 116. [PAN:AAFTA-2886-H] (अपीलाथ)/Appellant) (*+यथ)/Respondent) अपीलाथ) क, ओर से/Appellant by : Shri. G. Reddi Prakash, F.C.A. *+यथ) क, ओर से/Respondent by : Ms. Gouthami Manivasagam, J.C.I.T. सुनवाई क, तार"ख/Date of Hearing : 16.09.2025 घोषणा क, तार"ख/Date of Pronouncement : 23.10.2025 आदेश

ORGANISATION FOR REHABILITATION OF BLIND IN TRICHY,TIRUCHIRAPALLI vs. ITO, EXEMPTIONS WARD, TIRUCHIRAPALLI

In the result the appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:771/Chny/2025 धनिाारण वर्ा / Assessment Year: 2018-19 Organisation For Rehabilitation Of The Income-Tax Officer, Blind In Trichy, Vs. Exemption Ward, Tiruchirappalli. Racquet Court Lane, Near Central Bus Stand Junction, Tiruchirappalli – 620 001. [Pan:Aaato-1690-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. S. Sridhar, Advocate प्रत्यथी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit. सुनवाई की तारीख/Date Of Hearing : 03.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 05.08.2025

144B of the Act by making an addition of Rs.1,65,03,510/- and a demand of Rs.2,35,86,401/- was raised. The case of the Assessing Officer (AO) is that the assessee would fall under the category of “advancement of any other object of general public utility” in section 2(15) and accordingly proviso to section

YELCHUR VENKATA KOTAIAH CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1543/Chny/2024 (िनधा*रणवष* / Assessment Year: 2013-14) Yelchur Venkata Kotaiah Charities Cit (Exemption) बनाम/ 1, Audiappa Naicken Street, Chennai. Vs. George Town, Chennai-600 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaty-0056-C (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri J. Prabhakar (Fca) -Ld. Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 22-08-2024 घोषणाकीतारीख /Date Of Pronouncement : 04-09-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

144B of the Act on 19-03-2022. Having heard rival submissions, our adjudication would be as under. 2. It emerges that in assessment order dated 19-03-2022, Ld. AO observed that the assessee did not file return of income. Accordingly, the case was reopened and notice u/s 148 was issued to the assessee

CERONET EDUCATIONAL FOUNDATION,UDUMALPET vs. ACIT EXEMPTIONS, COIMBATORE

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

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)

charitable trust with a main object of imparting education irrespective caste, creed and religion which is the sole one and only object of the trust. As per the information available with the Income Tax 2014-2015 relevant to assessment year 2015-2016 and the same is as under:- ‘’Cash Deposit in IDBI Bank Limited Rs.1,26,94,628/-.’’ During

RANI ADAIKALARAJ EDUCATIONAL AND CHARITABLE TRUST ,TRICHY vs. ITO, EXEMPTIONS, TRICHY

In the result the assessee’s appeal is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 575/Chny/2024 िनधा"रणवष" / Assessment Year: 2018-19 Income Tax Officer, Rani Adaikalaraj Educational V. Exemption Ward & Charitable Trust, Income Tax Office, Represented By Managing 44, Williams Road, Cantonment, Trustee – A Joseph Francis, Trichy – 620 001. 7-B, Arokiasamypillai Lane, Crawford, Trichy – 620 012. [Pan:Aaatr-0494-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Mr. V.S. Jayakumar, Sr. Counsel For Ms.G. Vardinikarthik, Advocate & Mr. V. Arunachalesh, Advocate & Mr. R. Sumedha, Advocate ""यथ"क"ओरसे/Respondent By : Mr. R. Vikneswaran, Jcit सुनवाई क" तारीख/Date Of Hearing : 04.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 14.08.2024 आदेश /O R D E R

charitable purpose declared in its objects. The case was selected for scrutiny under CASS for verification of ‘receipts of trust’. The return of income filed was also processed u/s. 143(1) of the Act by rejecting the claim of deduction u/s. 11 of the Act and made an addition of Rs.71,77,551/-. Further, statutory notices were issued to proceed

M/S. SUSILA EDUCATIONAL TRUST,,VILLUPURAM vs. ITO (EXEMPTIONS), WARD-1,, CHENNAI

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

charitable or religious purposes\nor in part only for such purposes, or of income being voluntary\ncontributions referred to in sub-clause (iia) of clause (24) of section 2,\nshall, if the total income in respect of which he is assessable as a\nrepresentative assessee (the total income for this purpose being computed\nunder this Act without giving effect