THE GATE OF HOPE CHARITABLE TRUST,CHENNAI vs. ITO (EXEMPTIONS) WARD-2,, CHENNAI

The appeals of the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

1,10,58,707/ and claimed an amount of Rs. 1,10,58,707/- under Section 11 of the Income under Section 11 of the Income Tax Act. 2. Brief details of information received: 2. Brief details of information received: An information had been received from the DCIT(Exemptions), Chennai, vide An information had been received from the DCIT(Exemptions

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 Trust Vs Director of Income-tax (Exemption) [2008]71 Taxman 134 (Delhi) has held that when loans are advanced by the trust to any interested persons without security or adequate interest, the same amounts to conferring benefits directly or indirectly on the interested persons and is to be treated as violation of sections 13(1)(c) and 13(2

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 Trust Vs Director of Income-tax (Exemption) [2008]71 Taxman 134 (Delhi) has held that when loans are advanced by the trust to any interested persons without security or adequate interest, the same amounts to conferring benefits directly or indirectly on the interested persons and is to be treated as violation of sections 13(1)(c) and 13(2

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 Trust Vs Director of Income-tax (Exemption) [2008]71 Taxman 134 (Delhi) has held that when loans are advanced by the trust to any interested persons without security or adequate interest, the same amounts to conferring benefits directly or indirectly on the interested persons and is to be treated as violation of sections 13(1)(c) and 13(2

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 Trust Vs Director of Income-tax (Exemption) [2008]71 Taxman 134 (Delhi) has held that when loans are advanced by the trust to any interested persons without security or adequate interest, the same amounts to conferring benefits directly or indirectly on the interested persons and is to be treated as violation of sections 13(1)(c) and 13(2

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

2. The CIT (A) erred in holding that the payments made by the appellant trust to M/s Star Educational Trust, Mr Bharath Kumar and M/s Mahaajay Spinners India Private Limited are not eligible for deduction under section 11. 3. The CIT (A) officer failed to appreciate that the monies paid by the appellant trust to M/s Star Educational Trust

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

2. The CIT (A) erred in holding that the payments made by the appellant trust to M/s Star Educational Trust, Mr Bharath Kumar and M/s Mahaajay Spinners India Private Limited are not eligible for deduction under section 11. 3. The CIT (A) officer failed to appreciate that the monies paid by the appellant trust to M/s Star Educational Trust

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

Charitable Trust 1,12,53,64,017 5. Jayapriya Food products private limited 4,59,82,869 6. Jayapriya property developers private limited 2,43,54,370 7. Jayapriya Trading Company 8,26,56,356 8. Land Advance-APJ Abdulkalam Educational Trust 4,063,74,000 Total 1,61,89,97,220/- 10.4 It is observed that the assessee

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

Charitable Trust 1,12,53,64,017 5. Jayapriya Food products private limited 4,59,82,869 6. Jayapriya property developers private limited 2,43,54,370 7. Jayapriya Trading Company 8,26,56,356 8. Land Advance-APJ Abdulkalam Educational Trust 4,063,74,000 Total 1,61,89,97,220/- 10.4 It is observed that the assessee

M.P. SANTHOSH KUMAR, ITO, CHENNAI vs. GREENPEACE ENVIRONMENT TRUST, CHENNAI

In the result, appeal filed by the Revenue stands dismissed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 406/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2011-12 Income Tax Officer, Greenpeace Environment Trust, Exemptions, Ward-1, Vs. New No.49, Old No.23, Chennai. Ellaiamman Colony, Gopalapuram, Chennai-600 086. [Pan:Aaatg-3538-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. Kumar Chandan, Jcit. प्रत्यथी की ओर से/Respondent By : Shri. Y.Sridhar, F.C.A. सुनवाई की तारीख/Date Of Hearing : 19.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 25.08.2025 आदेश /O R D E R Per S. R. Raghunatha, Am :

2). 2.1 Under section 13(1)(c) if any income of a charitable trust enures or if any part of the income/property

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

2) of the Act He further held that once there was violation under section 13(1)(c), the trust would lose exemption under section 11 in respect of the other income also and thereby added Rs.19,59,537/-and taxed the same at maximum marginal rate. 5.5 The appellant has contended that the trust installed the Siemens CT Scanner

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 under\nsection 2(15) of the Act.\n40. Heard both the parties and perused the material available on\nrecords. On perusal of the assessment order, it is noted that the\nAssessing Officer reopened the assessment by issuing a notice dated\n23.09.2019 u/s 148 of the Act and by issuing notices under sections\n143(2) and 142(1

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 purposes defined u/s 2(15) or is it the last limb being an “object of general public utility” ; vide item No. 12 “Details of income accumulated under clause 2 of explanation to section 11(1)/11(2) having bearing on this assessment in the following format from the AY 2008-09 onwards; vide item No. 13, Please furnish unit

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)

2) applies to the whole or a part of the relevant income of a charitable or religious trust which forfeits exemption by virtue of the provisions of the Income-tax Act in regard to investment pattern or use of the trust property for the benefit of the settlor, etc., contained in section 13(1

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

In the result, the appeal stands allowed

sections": [ "11(4A)", "263", "11(1)", "2(15)", "11(4)", "13(1)(bb)" ], "issues": "Whether the petrol outlet business income of an educational trust can be considered incidental to its charitable

V.RAMAKRISHNA CHARITABLE TRUST,CHENNAI vs. DDIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. No.92/Mds/2015 ("नधा"रण वष" / Assessment Year : 2011-2012 )

2) of section-11 of the Act. 9. A charitable or religious trust have to apply 85% of income for the object of the trust so as to qualify for exemption u/s 11 of the Act. Income not exceeding 15% of income is allowed to be accumulated under this section 11(1

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 under\nsection 2(15) of the Act.\n40. Heard both the parties and perused the material available on\nrecords. On perusal of the assessment order, it is noted that the\nAssessing Officer reopened the assessment by issuing a notice dated\n23.09.2019 u/s 148 of the Act and by issuing notices under sections\n143(2) and 142(1

M. VELUSAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Charitable Trust", Trust", Trust", located located located at at at No.464, No.464, No.464, Vaiyapuri Vaiyapuri Vaiyapuri Nagar, Nagar, Nagar, 2nd 2nd 2nd Cross, Cross, Cross, Sengunthapuram, Sengunthapuram, Karur. The trust was established on 04.02.2011. Karur. The trust was established on 04.02.2011. The trustees (32 in Nos) bought 17.99 acres of land at Pungambadi The trustees (32 in Nos) bought