ACIT, EXEMPTIONS, COIMBATORE vs. MAHENDRA EDUCATIONAL TRUST, MANAKKAL

In the result, appeal filed by the Revenue is dismissed and cross objection filed by the assessee is allowed

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 125 & 126/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co Nos.: 18 & 19/Chny/2019 (In Ita Nos.125 & 126/Chny/2019) िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri N.V. Balaji, Advocate राज" की ओर से /Revenue By : Shri G. Chandrababu, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 28.01.2021 घोषणा क" तार"ख/Date Of Pronouncement : 11.02.2021

charitable purpose, he cannot disturb the same in subsequent assessment years. The CIT(A), further observed that as regards payment to Shri M.G. Bharathkumar, it was the claim of the assessee that Shri M.G. Bharathkumar has transferred the total amount to M/s. Star Educational Trust and said amount was used for the objects of the trust, which is having coming

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

section and not the entire income of the assessee trust to be taxed at maximum marginal rate u/s 164(2) of the Act. 17. The Hon'ble High Court of Delhi in the case of Kanahya Lal Punj Charitable

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

section and not the entire income of the assessee trust to be taxed at maximum marginal rate u/s 164(2) of the Act. 17. The Hon'ble High Court of Delhi in the case of Kanahya Lal Punj Charitable

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

section and not the entire income of the assessee trust to be taxed at maximum marginal rate u/s 164(2) of the Act. 17. The Hon'ble High Court of Delhi in the case of Kanahya Lal Punj Charitable

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

section and not the entire income of the assessee trust to be taxed at maximum marginal rate u/s 164(2) of the Act. 17. The Hon'ble High Court of Delhi in the case of Kanahya Lal Punj Charitable

M/S J SIKILE FOUNDATION,CHENNAI vs. DCIT, EXEMPTION-III, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.83/Chny/2022 िनधा"रणवष"/Assessment Year: 2011-12 V. M/S.J Sikile Foundation, The Dcit, Plot No.1025, Street No.44, Exemption-Iii, Tvs Colony, Anna Nagar West Extn., Chennai. Chennai-600 101. [Pan: Aaats 1630 C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

charitable and religious trusts are concerned, their business profits are not exempt from tax, except in the cases falling under clause (a) or clause (b) of section 11(4A) of the Income-tax Act. As the maximum marginal rate of tax under the new proviso to section 164

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

charitable purpose. 22. What we find is that ld. Commissioner of Income Tax (Appeals) had confirmed the addition u/s. 2(24)(xv) of the Act r.w.s. 56(2)(vii) of the Act. Both these Sections are reproduced hereunder:- Sec. 2(24) ‘’income includes--- (i)................ (ii).......................... (xv) any sum of money or value of property referred to in clause

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

charitable purpose. 22. What we find is that ld. Commissioner of Income Tax (Appeals) had confirmed the addition u/s. 2(24)(xv) of the Act r.w.s. 56(2)(vii) of the Act. Both these Sections are reproduced hereunder:- Sec. 2(24) ‘’income includes--- (i)................ (ii).......................... (xv) any sum of money or value of property referred to in clause

VYASA VIDYA MANDIRAM,COIMBATORE vs. CIT, EXEMPTIIONS,, CHENNAI

In the result, both the appeals of the assessee are allowed

charitable one.\nC. In Form 10AB, the Trust has described its objects as 'relief\nof the poor' and 'medical relief, but it has not indulged in any\nactivity involving 'relief of the poor' and medical relief.\n5. On the first ground of rejection, it may be noted that the Ld.\nCIT(E) failed to note that the assessee Trust

VYASA VIDYA MANDIRAM,COIMBATORE vs. CIT, EXEMPTIONS,, CHENNAI

In the result, both the appeals of the assessee are allowed

charitable one.\nC. In Form 10AB, the Trust has described its objects as 'relief\nof the poor' and 'medical relief, but it has not indulged in any\nactivity involving 'relief of the poor' and medical relief.\n5. On the first ground of rejection, it may be noted that the Ld.\nCIT(E) failed to note that the assessee Trust

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

164(2) of the Act He further held\nthat once there was violation under section 13(1)(c), the trust would lose\nexemption under section 11 in respect of the other income also and thereby\nadded Rs.19,59,537/-and taxed the same at maximum marginal rate.\n5.5 The appellant has contended that the trust installed the Siemens CT\nScanner

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

164(2) of the Act He further held\nthat once there was violation under section 13(1)(c), the trust would lose\nexemption under section 11 in respect of the other income also and thereby\nadded Rs.19,59,537/-and taxed the same at maximum marginal rate.\n5.5 The appellant has contended that the trust installed the Siemens CT\nScanner

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

Trust (supra). The Madras High Court by placing its reliance on the judgment of Rajasthan High Court in CIT v. 10 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 Maharana of Mewar Charitable Foundation (1987) 164 ITR 439 and on the judgment of Gujarat High Court in CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal

THE WILLINGDON CHARITABLE TRUST,CHENNAI vs. DDIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

Trust (supra). The Madras High Court by placing its reliance on the judgment of Rajasthan High Court in CIT v. 10 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 Maharana of Mewar Charitable Foundation (1987) 164 ITR 439 and on the judgment of Gujarat High Court in CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

Trust (supra). The Madras High Court by placing its reliance on the judgment of Rajasthan High Court in CIT v. 10 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 Maharana of Mewar Charitable Foundation (1987) 164 ITR 439 and on the judgment of Gujarat High Court in CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal

THE WILLINGDON CHARITABLE TRUST,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

Trust (supra). The Madras High Court by placing its reliance on the judgment of Rajasthan High Court in CIT v. 10 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 Maharana of Mewar Charitable Foundation (1987) 164 ITR 439 and on the judgment of Gujarat High Court in CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

Trust (supra). The Madras High Court by placing its reliance on the judgment of Rajasthan High Court in CIT v. 10 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 Maharana of Mewar Charitable Foundation (1987) 164 ITR 439 and on the judgment of Gujarat High Court in CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal

THE WILLINGDON CHARITABLE TRUST,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

Trust (supra). The Madras High Court by placing its reliance on the judgment of Rajasthan High Court in CIT v. 10 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 Maharana of Mewar Charitable Foundation (1987) 164 ITR 439 and on the judgment of Gujarat High Court in CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal