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

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

234). Further, the Supreme Court in the case of New\nNoble Education Society v. CCIT (143 taxmann.com 276)\nreaffirmed the narrow and restricted meaning of the term\n'Education' to a scholastic structured learning as confined\n(sic.-construed) in Articles 21A, 29-30 and 45-46 of the\nConstitution of India.\nB. The Trust is collecting fees for conducting

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

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

NRITYA SAMSRTI,CHENNAI vs. INCOME TAX OFFICER, CHENNAI

In the result the appeal of the assessee is allowed for statistical purposes

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.1064/Chny/2025 ननिाारण वर्ा/Assessment Year: Na V. Nritya Samsrti, Commissioner Of Income No.68/160, Big Street, Tax(Exemption), Triplicane, Chennai Chennai-600 005. [Pan: Aadtn4295P] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : अपीलार्थी की ओर से/ Appellant By Mr.Ashwini Vaidialingam प्रत्यर्थी की ओर से /Respondent By : Mr. Bipin C.N, Cit सुनवाईकीतारीख/Date Of Hearing : 21.07.2025 : घोर्णाकीतारीख /Date Of Pronouncement 23.07.2025

charitable nature of trusts engaged in the promotion of art and culture have consistently been upheld. 5. The Ld. CIT (Exemption) has erred in holding that teaching art forms cannot be considered as education under 5. 2(15). As per the decision of the Hon'ble Supreme Court in Sole Trustee, Loka Shikshana Trust vs. CIT, Mysore, 101 ITR 234

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

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 trusts ITA Nos.406 & 407/Mds/2017 :- 5 -: which lost exemption u/s. 11 & 12 of the Act. Further, as per ld. JCIT none of the trustees of the assessee trust nor its beneficiaries had come together with a common purpose of earning income and therefore it could not be treated as an AOP. According to the ld. JCIT, definition of person

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 trusts ITA Nos.406 & 407/Mds/2017 :- 5 -: which lost exemption u/s. 11 & 12 of the Act. Further, as per ld. JCIT none of the trustees of the assessee trust nor its beneficiaries had come together with a common purpose of earning income and therefore it could not be treated as an AOP. According to the ld. JCIT, definition of person

INVESTORS FINANCIAL EDUCATION ACADEMY,CHENNAI vs. ITO (EXEMPTION), CHENNAI

In the result, the appeal of the assessee is dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No.2565/Chny/2017 "नधा"रण वष" /Assessment Year : ---

Trust vs. CIT, 101 ITR 234. We have considered the rival contentions and perused the 7. orders of the authorities below. Before adverting to the facts, it will be apposite to extract Section 2(15) of the Act which defined charitable

NARADA GANA SABHA TRUST,CHENNAI vs. ITO EXEMPTIONS WARD-1,, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकरअपीलसं./Ita No.463/Chny/2023 िनधा"रणवष"/Assessment Year: 2018-19 Narada Gana Sabha Trust, The Income Tax Officer- V. No.314, T.T.K.Road, (Exemptions), Alwarpet, Ward-1, Chennai-600 018. Chennai. [Pan: Aaatn 0417 C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

234 (SC). Therefore, we cannot agree with the arguments of the ld.Counsel of the asseessee the objects and activities of the Trust falls under the definition of sec.2(15) of the Act. Further, it is an admitted fact that the assessee is a famous Gana Sabha Trust and organizes music competitions, concerts and also provide platform for various young Musicians

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

234 81 repaid by CH/DD 25% 21% 38% No. of student fee 644 881 130 advances repaid by CH/DD 75% 79% 62% ii. Appellants submission in paras 2.1 to 2.13 extracted above/ explaining the need for repayment of Student advances & Advance tuition fees in cash can be appreciated in the light of the above statistics for the 3 years

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

234 81 repaid by CH/DD 25% 21% 38% No. of student fee 644 881 130 advances repaid by CH/DD 75% 79% 62% ii. Appellants submission in paras 2.1 to 2.13 extracted above/ explaining the need for repayment of Student advances & Advance tuition fees in cash can be appreciated in the light of the above statistics for the 3 years

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

234 81 repaid by CH/DD 25% 21% 38% No. of student fee 644 881 130 advances repaid by CH/DD 75% 79% 62% ii. Appellants submission in paras 2.1 to 2.13 extracted above/ explaining the need for repayment of Student advances & Advance tuition fees in cash can be appreciated in the light of the above statistics for the 3 years

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

234 81 repaid by CH/DD 25% 21% 38% No. of student fee 644 881 130 advances repaid by CH/DD 75% 79% 62% ii. Appellants submission in paras 2.1 to 2.13 extracted above/ explaining the need for repayment of Student advances & Advance tuition fees in cash can be appreciated in the light of the above statistics for the 3 years

DOLPHIN CLUB,CHENNAI vs. CIT EXEMPTIONS, CHENNAI

The appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकरअपीलसं. Ita No 3107/Chny/2024 "नधा"रणवष"/Assessment Years: -- Dolphin Club V. Cit, (E), 3/15, Jeswanth Nagar, Mogappiar No. 121, Mahatma Gandhi West,Chennai-600037 Road, Nungambakkam Chennai-600034 [Pan: Aaatd 0288 P] (अपीलाथ"/Assessee) (""यथ"/Respondent)

Trust v. CIT (1975) 101 ITR 234, the term “education” under section 2(15) refers to systematic instruction, schooling, or training imparted to the young to prepare them for life, and includes scholastic instruction received through a structured course of study. The term is not intended to cover every form of knowledge acquisition in its widest sense.If the term “education

EQUITAS DEVELOPMENT INITIATIVES TRUST,CHENNAI vs. ITO EXEMPTION WARD-3, CHENNAI

In the result, the appeals filed for all three assessment years are allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2582, 2583 & 2082/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13 & 2013-14

section 13(8) prohibits applicability of sec.11 &12 in respect of any income of the society and is not restricted to the business activity of trust. Therefore, the surplus derived by the trust is entire brought to taxation.” 4. Being aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). Before

EQUITAS DEVELOPMENT INITIATIVES TRUST,CHENNAI vs. ITO EXEMPTION WARD-3, CHENNAI

In the result, the appeals filed for all three assessment years are allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2582, 2583 & 2082/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13 & 2013-14

section 13(8) prohibits applicability of sec.11 &12 in respect of any income of the society and is not restricted to the business activity of trust. Therefore, the surplus derived by the trust is entire brought to taxation.” 4. Being aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). Before

EQUITAS DEVELOPMENT INITIATIVES TRUST,CHENNAI vs. ITO EXEMPTION WARD-3, CHENNAI

In the result, the appeals filed for all three assessment years are allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2582, 2583 & 2082/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13 & 2013-14

section 13(8) prohibits applicability of sec.11 &12 in respect of any income of the society and is not restricted to the business activity of trust. Therefore, the surplus derived by the trust is entire brought to taxation.” 4. Being aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). Before