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

40 ITR 746 (ITAT-Chennai) it was held as under:- ITA Nos.1302 to 1304/Chny/2023 (AYs 2014-15 to 2016-17) CO Nos.1 to 3/Chny/2024 (AYs 2014-15 to 2016-17) M/s.D.N. Public Charitable Trust :: 27 :: Entitlement to exemption under section

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. TAMILNADU STATE MARKETING CORPORATION LIMITED, TAMIL NADU (CHENNAI)

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Section 40 between a tax and a fee will be obliterated and rendered meaningless. It is settled principle of interpretation that where the same Statute, uses different terms and expressions, then it is clear that Legislature is referring to distinct and different things. To support the said view ready reference can be made to judgments of this Court

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 status is immaterial. She argued that the exemption under section 11 of the Act is assessed based on current year activities but not past or future intention as held by the Hon’ble Supreme Court in the case of Baba Banda Singh Bahadur Education Trust reported in [2023] 150 Taxmann.com 40

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

Charitable Trust v. DCIT reported in\n[2015] 40 ITR 746 (ITAT-Chennai) it was held as under:-\nEntitlement to exemption under section

RANE ENGINE VALVE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5(1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

40(a)(i) of the Act as no TDS deducted on the above payment. The assessee replied that during the year the assessee company has contributed to JUSE in connection with 60th Anniversary deming prize conducted by JUSE. The contribution is made for publication and ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 advertisement in Japan

RANE ENGINE VALVE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5 (1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

40(a)(i) of the Act as no TDS deducted on the above payment. The assessee replied that during the year the assessee company has contributed to JUSE in connection with 60th Anniversary deming prize conducted by JUSE. The contribution is made for publication and ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 advertisement in Japan

RANE ENGINE VALVE LTD,CHENNAI vs. DCIT CORPORATE CIRCLE-5(1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

40(a)(i) of the Act as no TDS deducted on the above payment. The assessee replied that during the year the assessee company has contributed to JUSE in connection with 60th Anniversary deming prize conducted by JUSE. The contribution is made for publication and ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 advertisement in Japan

RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

40(a)(i) of the Act as no TDS deducted on the above payment. The assessee replied that during the year the assessee company has contributed to JUSE in connection with 60th Anniversary deming prize conducted by JUSE. The contribution is made for publication and ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 advertisement in Japan

RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

40(a)(i) of the Act as no TDS deducted on the above payment. The assessee replied that during the year the assessee company has contributed to JUSE in connection with 60th Anniversary deming prize conducted by JUSE. The contribution is made for publication and ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 advertisement in Japan

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

Charitable Trust v. DCIT reported in\n[2015] 40 ITR 746 (ITAT-Chennai) it was held as under:-\nEntitlement to exemption under section

M/S INNOVTIVE MICROFINANCE FOR POVERTY ALLEVIATION,CHENNAI vs. DCIT(EXEMPTIONS),CHENNAI CIRCLE, CHENNAI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Mahavir Singhand Shri Jagadish

40 DTR 153 (Visakha-Trib.) which held that micro finance activity is a charitable activity as it alleviates poverty and also benefits socio-economically weaker sections of the society. The Hon'ble Tribunal held that the Micro finance activity was charitable in nature because of the following reasons: (i) The loan is advanced to weaker sections of the society

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 status is immaterial. She argued that the exemption\nunder section 11 of the Act is assessed based on current year activities\nbut not past or future intention as held by the Hon'ble Supreme Court in\nthe case of Baba Banda Singh Bahadur Education Trust reported in\n[2023] 150 Taxmann.com 40

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 status is immaterial. She argued that the exemption\nunder section 11 of the Act is assessed based on current year activities\nbut not past or future intention as held by the Hon'ble Supreme Court in\nthe case of Baba Banda Singh Bahadur Education Trust reported in\n[2023] 150 Taxmann.com 40

M/S. INNOVATIVE MICRFINANCE FOR POVERTY ALLEVIATION & COMMUNITY TRANSFORMATION,CHENNAI vs. CIT, EXEMPTIONS,, CHENNAI

In the result, the appeal of the assessee is dismissed

40 DTR 153 (Visakha-Trib.) which held that micro finance activity is a\ncharitable activity as it alleviates poverty and also benefits socio-economically\nweaker sections of the society. The Hon'ble Tribunal held that the Micro finance\nactivity was charitable in nature because of the following reasons:\n(i) The loan is advanced to weaker sections of the society

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

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

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

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