INCOME TAX OFFICER , BIBIKULAM MADURAI vs. D N PUBLIC CHARITABLE TRUST, ARASARADI MADURAI TAMIL NADU

In the result, Cross Objections filed by the assessee are partly

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

Trust, the consequential invocation of provisions in Section 147 of the Act should be reckoned as bad in law. 5. The NFAC, Delhi failed to appreciate that mechanical approval by the competent authority in terms of Section 151 of the Act for the purpose of initiating re-assessment proceedings would vitiate the consequential re- assessment order passed in view

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

In the result, the appeal stands allowed

charitable objects. He showed us that, the\ndecision of New Noble was rendered specifically in the context of\neducational institutions claiming exemption u/s 10(23C)(vi) of the Act\nwhich required these institutions to be engaged \"solely\" in educational\nactivities and not for the purposes of profits. Shri Muralidhar explained\nthat, in the absence of any such restrictive condition laid

INCOME TAX OFFICER, BIBIKULAM MADURAI vs. D N PUBLIC CHARITABLE TRUST, ARASARADI MADURAI TAMIL NADU

Charitable Trust, a sum of Rs.15.11 Lacs is\nreceivable from the company M/s. Dhevaki Diagnostic Private Limited for the\nAsst. Year: 2016-17, due to the reason of last 4 months (Dec 15 to Mar 16) CT\nScan fee bills collected by the company and to be remitted to the trust\notherwise there is no direct flow/lent of money

INCOME TAX OFFICER, BIBIKULAM MADURAI vs. D N PUBLIC CHARITABLE TRUST, ARASARADI MADURAI TAMIL NADU

In the result, appeals filed by the Revenue are dismissed\nand Cross Objections filed by the assessee are partly allowed

charitable purposes. The Tribunal found no evidence that the company M/s. DDPL retained any fees for the CT scanner's use, and all collected fees were transferred to the assessee trust. The AO's estimation of compensation was based on flawed data, and the claim of violation of Section 13(1)(c) was not substantiated. The Tribunal also ruled that

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 in nature and its commercial activities are neither prohibited nor restricted by the section 2(15) of the Act. The Chennai ITAT benches clarified the same vide order dated 18.11.2024 in the case of Smt. Lingammal Ramaraju Shastra Prathistha Trust reported in 168 taxmann.com 476 (Chennai Tribunal). 31. Further he drew attention to the decision of Hon’ble Supreme

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. The ld. 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

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. The ld. 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

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

151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating the interface between the Income Tax Authorities and assessee. Sub-section 3 of Section 151A of the Act also provides that every notification issued under sub-section (1) and (2) of Section 151A of the Act shall be laid before each House of Parliament. In exercise

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

151; So as to impart greater efficiency, transparency and accountability by inter alia eliminating the interface between the Income Tax Authorities and assessee. Sub-section 3 of Section 151A of the Act also provides that every notification issued under sub-section (1) and (2) of Section 151A of the Act shall be laid before each House of Parliament. In exercise

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 in nature and its commercial activities are\nneither prohibited nor restricted by the section 2(15) of the Act. The\nChennai ITAT benches clarified the same vide order dated 18.11.2024 in\nthe case of Smt. Lingammal Ramaraju Shastra Prathistha Trust reported\nin 168 taxmann.com 476 (Chennai Tribunal).\n31. Further he drew attention to the decision of Hon'ble Supreme

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 in nature and its commercial activities are\nneither prohibited nor restricted by the section 2(15) of the Act. The\nChennai ITAT benches clarified the same vide order dated 18.11.2024 in\nthe case of Smt. Lingammal Ramaraju Shastra Prathistha Trust reported\nin 168 taxmann.com 476 (Chennai Tribunal).\n31. Further he drew attention to the decision of Hon'ble Supreme

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

Trust without\nbringing any prima facie evidence on record to prove that those alleged receipts are\nnot donations but \"capitation fee\" as held in the case of MAC Public Charitable\nTrust. The Id. Counsel for the assessee further argued that the PCIT ought to have\napplied his mind before passing the order directing the AO to deny exemption

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. A. SRINIVASAN, PERAMBALUR

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

Charitable & Educational Trust on 15.02.2018 and the amendment made by Parliament as per Finance Act 2017 w.e.f. 01.04.2017 in the relevant provisions also applies and needs to be also considered. 7. The relevant provisions of section 153A and 153C of the Act are reproduced below: 153A. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section

ARUNACHALAM SRINIVASAN,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-1 , TRICHY

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

Charitable & Educational Trust on 15.02.2018 and the amendment made by Parliament as per Finance Act 2017 w.e.f. 01.04.2017 in the relevant provisions also applies and needs to be also considered. 7. The relevant provisions of section 153A and 153C of the Act are reproduced below: 153A. (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section

M/S. AARK INDIA EDUCATIONAL TRUST,TIRUNELVELI vs. ITO (EXEMPTIONS), TIRUNELVELI

In the result, the appeal of the asse

Bench: Shri Manu Kumar Giri & Shris.R.Raghunathaआयकरअपीलसं/.Ita Nos.: 1986/Chny/2025 "नधा"रणवष" / Assessment Year: 2012-13 Aark India Educational V. Income Tax Officer Charitable Trust, (Exemptions Ward) Nellai 1 1 Francis Xavier Engineering City Centre, Rahmath Nagar, College Campus, Vannarapettai, Tiruchendur Road, Tirunelveli, Tamil Nadu Tirunelveli Tamil Nadu- 627003 627011 [Pan: Aacta 2809 D] (अपीलाथ /Appellant) (!"यथ /Respondent) आयकरअपीलसं/.Ita No. 2387/Chny/2025 (Revenue Appeal) "नधा"रणवष" / Assessment Year: 2012-13 Income Tax Officer (Exemptions Aark India Educational Ward) Nellai City Centre, Rahmath Charitable Trust, Nagar, Tiruchendur Road, 1 1 Francis Xavier Tirunelveli Tamil Nadu-627011 Engineering College Campus, Vannarapettai, Tirunelveli, Tamil Nadu-627003 [Pan: Aacta 2809 D] (अपीलाथ /Appellant) (!"यथ /Respondent) अपीलाथ क$ओरसे/Appellant/Assessee By : Mr. Y. Sridhar, F.C.A. : Ms. E. Pavuna Sundari, Cit !"यथ क$ओरसे/Respondent/Revenue By सुनवाईक$तार"ख/Date Of Hearing : 07.01.2026

charitable trust based in Tirunelveli and has been granted registration u/s. 12AA of the Income Tax Act with effect from 12AA of the Income Tax Act with effect from 12AA of the Income Tax Act with effect from Assessment Year 2013- -14. The Trust, established on 23.08.2007, 14. The Trust, established on 23.08.2007, operates on a non-profit basis with

INCOMETAX OFFICER EXEMPTIONS WARD, TIRUNELVELI vs. AARK INDIA EDUCATIONAL CHARITABLE TRUST, TIRUNELVELI

In the result, the appeal of the asse

Bench: Shri Manu Kumar Giri & Shris.R.Raghunathaआयकरअपीलसं/.Ita Nos.: 1986/Chny/2025 "नधा"रणवष" / Assessment Year: 2012-13 Aark India Educational V. Income Tax Officer Charitable Trust, (Exemptions Ward) Nellai 1 1 Francis Xavier Engineering City Centre, Rahmath Nagar, College Campus, Vannarapettai, Tiruchendur Road, Tirunelveli, Tamil Nadu Tirunelveli Tamil Nadu- 627003 627011 [Pan: Aacta 2809 D] (अपीलाथ /Appellant) (!"यथ /Respondent) आयकरअपीलसं/.Ita No. 2387/Chny/2025 (Revenue Appeal) "नधा"रणवष" / Assessment Year: 2012-13 Income Tax Officer (Exemptions Aark India Educational Ward) Nellai City Centre, Rahmath Charitable Trust, Nagar, Tiruchendur Road, 1 1 Francis Xavier Tirunelveli Tamil Nadu-627011 Engineering College Campus, Vannarapettai, Tirunelveli, Tamil Nadu-627003 [Pan: Aacta 2809 D] (अपीलाथ /Appellant) (!"यथ /Respondent) अपीलाथ क$ओरसे/Appellant/Assessee By : Mr. Y. Sridhar, F.C.A. : Ms. E. Pavuna Sundari, Cit !"यथ क$ओरसे/Respondent/Revenue By सुनवाईक$तार"ख/Date Of Hearing : 07.01.2026

charitable trust based in Tirunelveli and has been granted registration u/s. 12AA of the Income Tax Act with effect from 12AA of the Income Tax Act with effect from 12AA of the Income Tax Act with effect from Assessment Year 2013- -14. The Trust, established on 23.08.2007, 14. The Trust, established on 23.08.2007, operates on a non-profit basis with

RAMASAMI PALANISAMY,TIRUPUR vs. ITO, WARD-2(1), ERODE

In the result, appeal filed by the assessee is allowed

Charitable Trust for the\nsame year (AY 2016-17) as excess consideration.\n10. After considering the material available on record and the reply of the\nassessee, I am satisfied that it is not a fit case for issue of notice u/s.148 of\nthe I.T. Act. This order u/s.148A(d) is issued with the prior approval of\nDGIT(Inv), Chennai

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SUBRAMANIAM KATHIRESAN, CHENNAI

In the result, appeal filed by the Revenue for AY 2014-15 is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish within such period, as may be specified