NEURO UPDATE CHENNAI,CHENNAI vs. ITO, EXEMPTION WARD-1, CHENNAI

In the result, the appeal of the assessee is allowed

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

charitable intent, as the benefit accrues to advancement of medical science :-12-: ITA. No:1480 /Chny/2025 for public health. Thus, the requirement under Section 2(15) of the Act is satisfied. 14. The AO has cited the Supreme Court's observation in Sole Trustee, Lok Shikshana Trust v. CIT [101 ITR 234] to infer that "education" must involve formal, scholastic

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)

section. However, ld. JCIT was not impressed by any of the above 5. arguments taken by the assessee. According to him, Explanation to Sec. 2(31) of the Act, introduced by Finance Act, 2002, was only to bring within the ambit of taxation, religious and/ or charitable trusts ITA Nos.406 & 407/Mds/2017 :- 5 -: which lost exemption

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)

section. However, ld. JCIT was not impressed by any of the above 5. arguments taken by the assessee. According to him, Explanation to Sec. 2(31) of the Act, introduced by Finance Act, 2002, was only to bring within the ambit of taxation, religious and/ or charitable trusts ITA Nos.406 & 407/Mds/2017 :- 5 -: which lost exemption

ITO(EXCEMPTION) TRICHY, TRICHY vs. GRAMA VIDIYAL TRUST, TRICHY

In the result, both ITA No

Bench: Shri Veeravalli Durga Rao, Jm & Shri Girish Agrawalita Nos.1534 & 1535/Chny/2019 Assessment Years: 2009-10 & 2011-12 Income-Tax Officer, Grama Vidiyal Trust, (Exemptions), Trichy Vs. No. 44, Williams Road, Cantonment, Trichy-620001 (Pan: Aaatg2928F) (Appellant) (Respondent) Present For: Appellant By : Shri N. V. Balaji, Advocate Respondent By : Shri Arv. Sreenivasan, Addl. Cit Date Of Hearing : 31.05.2022 Date Of Pronouncement : 24.08.2022 O R D E R Per Girish Agrawal: Both These Appeals By Revenue Are Directed Against The Separate Orders Of Ld. Cit(A)-1, Trichy Vide Ita No. 156/2017-18/Cit(A)-1/Try Dated 04.03.2019 & 163/2017-18/Cit(A)-1/Try Dated 22.02.2019 Against The Separate Orders Of Ld. Ito, Exemptions Ward, Trichy, Passed U/S 143(3) R.W.S. 254 Of The Income-Tax Act,1961 (Hereinafter Referred To As The Act), Both Dated 30.12.2017 For Ays 2009-10 & 2011-12. 2. First We Take Up Ita No. 1534/Chny/2019 For Ay 2009-10 For Which The Revised Ground Taken By The Revenue Is As Under:

section 11(1A) of the Income-tax Act, 1961, are not applicable in those cases where exemption u/s. 11 of the Income-tax Act, 1961, was denied.” 3 Brief facts as culled out from the record are that Grama Vidiyal Trust (in short “GVT”) was created as a public charitable trust on 01.04.1997 which was granted 12AA registration

ITO(EXCEMPTION) TRICHY, TRICHY vs. GRAMA VIDIYAL TRUST, TRICHY

In the result, both ITA No

Bench: Shri Veeravalli Durga Rao, Jm & Shri Girish Agrawalita Nos.1534 & 1535/Chny/2019 Assessment Years: 2009-10 & 2011-12 Income-Tax Officer, Grama Vidiyal Trust, (Exemptions), Trichy Vs. No. 44, Williams Road, Cantonment, Trichy-620001 (Pan: Aaatg2928F) (Appellant) (Respondent) Present For: Appellant By : Shri N. V. Balaji, Advocate Respondent By : Shri Arv. Sreenivasan, Addl. Cit Date Of Hearing : 31.05.2022 Date Of Pronouncement : 24.08.2022 O R D E R Per Girish Agrawal: Both These Appeals By Revenue Are Directed Against The Separate Orders Of Ld. Cit(A)-1, Trichy Vide Ita No. 156/2017-18/Cit(A)-1/Try Dated 04.03.2019 & 163/2017-18/Cit(A)-1/Try Dated 22.02.2019 Against The Separate Orders Of Ld. Ito, Exemptions Ward, Trichy, Passed U/S 143(3) R.W.S. 254 Of The Income-Tax Act,1961 (Hereinafter Referred To As The Act), Both Dated 30.12.2017 For Ays 2009-10 & 2011-12. 2. First We Take Up Ita No. 1534/Chny/2019 For Ay 2009-10 For Which The Revised Ground Taken By The Revenue Is As Under:

section 11(1A) of the Income-tax Act, 1961, are not applicable in those cases where exemption u/s. 11 of the Income-tax Act, 1961, was denied.” 3 Brief facts as culled out from the record are that Grama Vidiyal Trust (in short “GVT”) was created as a public charitable trust on 01.04.1997 which was granted 12AA registration

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

In the result, appeal filed by the assessee is allowed

Charitable Trust as well. Consequent to the\nsearch, notice u/s 153A of the Act was issued to Mr. TSRK inter alia for AY\n2016-17 as well, and that Mr.TSRK in the return filed in response to\nnotice u/s 153A for AY 2016-17 on 10.08.2021, copy of which was placed\nat Page Nos.46-48 of the paper book, declared total

DCIT, COIMBATORE vs. ST. XAVIER EDUCATIONAL & CHARITABLE TRUST, TIRUNELVELI

In the result, the appeal of the Revenue stands dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No.1192/Chny/2017 "नधा"रण वष" /Assessment Year : 2013-2014

Charitable Trust, Exemptions No.103/G2, Bye Pass Road, Coimbatore Vannarapettai, Tirunelveli 627 003. [PAN AABTS 1867L] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. AR.V. Sreenivasan, IRS, JCIT. अपीलाथ" क" ओर से/ Appellant by : Mrs. S. Vidya, C.A. ""यथ" क" ओर से /Respondent by सुनवाई क" तार"ख/Date of Hearing : 23-04-2018 घोषणा क" तार"ख /Date of Pronouncement

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

221 Interest W/off 8.12 It is seen that, even the AO has acknowledged in the impugned order that, the bad debts written off, was out of the interest income offered to tax in the earlier years. In our considered view therefore, the twin conditions laid down in Section 36(2) r.w. 36(1)(vii) of the Act was fulfilled

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

221 Interest W/off 8.12 It is seen that, even the AO has acknowledged in the impugned order that, the bad debts written off, was out of the interest income offered to tax in the earlier years. In our considered view therefore, the twin conditions laid down in Section 36(2) r.w. 36(1)(vii) of the Act was fulfilled

ACIT, TRICHY vs. SHRI R.VISWANATHAN, DINDIGUL

Bench: Shri Chandra Poojari & Shri V. Durga Rao

Charitable Trust (in short I.T.A.Nos.2036 & 2037, 2039 :- 4 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. SPRECT), Tanjore in order to unearth the link between the said trust and the Titan Educational Trust [in short TET]. Later, on 05/10/06 there was a search in the residence of the assessee and survey operation on the educational institutions

ACIT, TRICHY vs. SHRI P.JANAKAR, DINDIGUL

Bench: Shri Chandra Poojari & Shri V. Durga Rao

Charitable Trust (in short I.T.A.Nos.2036 & 2037, 2039 :- 4 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. SPRECT), Tanjore in order to unearth the link between the said trust and the Titan Educational Trust [in short TET]. Later, on 05/10/06 there was a search in the residence of the assessee and survey operation on the educational institutions

SRI PONNAIYAH RAMAJAYATHAMMAL EDUCTIONAL & CHARITABLE TRUST,CHENNAI vs. ACIT, TRICHY

Bench: Shri Chandra Poojari & Shri V. Durga Rao

Charitable Trust (in short I.T.A.Nos.2036 & 2037, 2039 :- 4 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. SPRECT), Tanjore in order to unearth the link between the said trust and the Titan Educational Trust [in short TET]. Later, on 05/10/06 there was a search in the residence of the assessee and survey operation on the educational institutions

ACIT, TRICHY vs. P.MURUGESAN, THANJAVUR

Bench: Shri Chandra Poojari & Shri V. Durga Rao

Charitable Trust (in short I.T.A.Nos.2036 & 2037, 2039 :- 4 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. SPRECT), Tanjore in order to unearth the link between the said trust and the Titan Educational Trust [in short TET]. Later, on 05/10/06 there was a search in the residence of the assessee and survey operation on the educational institutions

P.MURUGESAN,CHENNAI vs. ACIT, TRICHY

Bench: Shri Chandra Poojari & Shri V. Durga Rao

Charitable Trust (in short I.T.A.Nos.2036 & 2037, 2039 :- 4 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. SPRECT), Tanjore in order to unearth the link between the said trust and the Titan Educational Trust [in short TET]. Later, on 05/10/06 there was a search in the residence of the assessee and survey operation on the educational institutions

KELLER (M) SDN BHD,CHENNAI vs. DCIT INTL TAX 1(2), CHENNAI, CHENNAI

In the result, the appeal of the assessee stands allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1319/Chny/2023 (िनधा"रणवष" / Assessment Year: 2018-2019) Vs. The Deputy Commissioner Of Keller (M) Sdn Bhd, Income Tax, 7Th Floor, Centennial Square, International Taxation 1(2) No.6A, Dr. Ambedkar Road, Chennai. Kodambakkam, Chennai 600 024. [Pan: Aagck 8014M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Ashik Shah, C.A. ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit.

221 2022, issued by the Ld. AO 7.2. Statement of computation of income of the Appellant for AY 225 2018-19 7.3. Financial statements of the Appellant for FY 2017-18 230 8 Submission dated March 21, 2023, filed with the AO in response 233 to the show cause notice ("SCN") dated March 18, 2023 issued

MR. N. NACHIMUTHU,SALEM vs. ITO, SALEM

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

Bench: Shri Chandra Poojari & Shri Duvvuru R.L Reddy

Section 221 (1) of the Income Tax Act, 1961, (in short ‘the Act’) on 18.06.2014 from the Assessing Officer to appear before him on 27.06.2014, in connection with the demand of ₹36,24,480/-. Then only, the assessee came to know about the seriousness of the issue and the assessee filed the appeal challenging the assessment order. Thus there

MANSI FINANCE CHENNAI LIMITED,CHENNAI vs. THE ACIT, CC 4(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 108 & 109/Chny/2021 िनधा"रण वष"/Assessment Years: 2012-13 & 2013-14

Charitable Trust v. DCIT 280 ITR 357 (Mad) held that no hard and fast rule can be laid down in the matter of condonation of delay and the Court should adopt a pragmatic approach and the Court should exercise their discretion on the facts of each case keeping in mind that in construing the expression "sufficient cause" the principle

MANSI FINANCE CHENNAI LIMITED,CHENNAI vs. THE ACIT, CC-4(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 108 & 109/Chny/2021 िनधा"रण वष"/Assessment Years: 2012-13 & 2013-14

Charitable Trust v. DCIT 280 ITR 357 (Mad) held that no hard and fast rule can be laid down in the matter of condonation of delay and the Court should adopt a pragmatic approach and the Court should exercise their discretion on the facts of each case keeping in mind that in construing the expression "sufficient cause" the principle