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 Trust (supra), we hold the activity of sale of uniforms, textbooks, etc. and the excess of income over expenditure arising thereon which are disclosed in Form-10A are incidental to the attainment of objects of the assessee. Therefore, the assessee is entitled to the benefit of section 11 of the Act for the year under consideration, accordingly, we hold

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order 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 Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

Charitable Trust (supra), we hold the activity of sale of uniforms, textbooks, etc. and the excess of income over expenditure arising thereon which are disclosed in Form-10A are incidental to the attainment of objects of the assessee. Therefore, the assessee is entitled to the benefit of section 11 of the Act for the year under consideration, accordingly, we hold

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

charitable trusts registered u/s 12A of the Act; (d) that the decision of the Hon'ble Supreme Court in the case of Thanthi Trust continued to hold good and was applicable to the assessee's case and that the decisions rendered in the cases of AUDA and New Noble didn't over-rule Thanthi Trust, which was rendered

P. KARUNANITHI,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

K. PARAMASIVAM,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

K. BASKAR,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

K. SADASIVAM,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

R.EASWARAMOORTHY,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

K. KATHIRVEL,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

RAMASAMY PALANISAMY,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

RAMASAMY PALANISAMY,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

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

S. EASWARAMOORTHY,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

M. NATESAN,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

S. ARAVIND,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

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

P. NALLUSAMY,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

K. BASKAR,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

THE CHRISTIA LITERATURE SOCIETY,CHENNAI vs. JCIT (OSD), CHENNAI

In the result, I set aside the orders of the lower authorities

Bench: Shri Abraham P. George]

section 25 of the Companies Act. Sec. 11(1) of the Act does not say that only a trust is be eligible for claiming exemption mentioned therein. It only say that income should be derived from property held under trust. There is no case for the Revenue that the property held by assessee in the status of the company u/s.25