KARUNYA EDUCATIONAL AND RESEARCH TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(1), CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकरअपील सं./Ita Nos.799/Chny/2025, Assessment Year: 2017-18 आयकरअपील सं./Ita Nos.800/Chny/2025, Assessment Year: 2018-19 आयकरअपील सं./Ita Nos.801/Chny/2025, Assessment Year: 2019-20 आयकरअपील सं./Ita Nos.802/Chny/2025, Assessment Year: 2020-21 आयकरअपील सं./Ita Nos.803/Chny/2025, Assessment Year: 2021-22 Karunya Educational & Vs. Deputy Commissioner Of Income Tax, Research Trust, Central Circle-3(1), No.16, Dr.D.G.S.Dhinakaran Road, Chennai. Raja Annamalaipuram, Chennai-600 028. [Pan:Aaatk0225H] (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. V.Nagaprasad, Advocate & Ms.S.Revathy, F.C.A. प्रत्यर्थी की ओर से /Respondent By : Mr. M.K.Biju, Cit Dr सुनवाई की तारीख/Date Of Hearing : 05.06.2025 घोषणा की तारीख /Date Of Pronouncement : 07.07.2025

charitable Trust. There was a search u/s.132 of the Act on 20.01.2021 in the case of the Assessee and it’s associate M/s.Jesus Calls. During the search various books of accounts, loose sheets / electronic devices found and seized. 4. The Assessee had used software named as ‘Campus Management System’ (CMS) developed by Dimensions Innovations Lab, Kerala in the early years

KARUNYA EDUCATIONAL AND RESEARCH TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(1), CHENNAI

In the result all the five appeals of the assessee for A

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.799/Chny/2025, Assessment Year: 2017-18 आयकर अपील सं./Ita Nos.800/Chny/2025, Assessment Year: 2018-19 आयकर अपील सं./Ita Nos.801/Chny/2025, Assessment Year: 2019-20 आयकर अपील सं./Ita Nos.802/Chny/2025, Assessment Year: 2020-21 आयकर अपील सं./Ita Nos.803/Chny/2025, Assessment Year: 2021-22 Karunya Educational & Research Trust, No.16, Dr.D.G.S.Dhinakaran Road, Raja Annamalaipuram, Chennai-600 028. [Pan:Aaatk0225H] (अपीलार्थी/Assessee) Vs. Deputy Commissioner Of Income Tax, Central Circle-3(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. V.Nagaprasad, Advocate & Ms.S.Revathy, F.C.A. प्रत्यर्थी की ओर से / Respondent By : Mr. M.K.Biju, Cit Dr सुनवाई की तारीख/Date Of Hearing : 05.06.2025 घोषणा की तारीख / Date Of Pronouncement : 07.07.2025 Per Bench आदेश / Order 1. These Five Appeals In Ita Nos.799/Chny/2025 To 803/Chny/2025 For

charitable Trust. There was a search u/s.132 of the Act on 20.01.2021 in the case of the Assessee and it's associate M/s.Jesus Calls. During the search various books of accounts, loose sheets / electronic devices found and seized. 4. The Assessee had used software named as 'Campus Management System' (CMS) developed by Dimensions Innovations Lab, Kerala in the early years

KARUNYA EDUCATIONAL AND RESEARCH TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(1), CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकरअपील सं./Ita Nos.799/Chny/2025, Assessment Year: 2017-18 आयकरअपील सं./Ita Nos.800/Chny/2025, Assessment Year: 2018-19 आयकरअपील सं./Ita Nos.801/Chny/2025, Assessment Year: 2019-20 आयकरअपील सं./Ita Nos.802/Chny/2025, Assessment Year: 2020-21 आयकरअपील सं./Ita Nos.803/Chny/2025, Assessment Year: 2021-22 Karunya Educational & Vs. Deputy Commissioner Of Income Tax, Research Trust, Central Circle-3(1), No.16, Dr.D.G.S.Dhinakaran Road, Chennai. Raja Annamalaipuram, Chennai-600 028. [Pan:Aaatk0225H] (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. V.Nagaprasad, Advocate & Ms.S.Revathy, F.C.A. प्रत्यर्थी की ओर से /Respondent By : Mr. M.K.Biju, Cit Dr सुनवाई की तारीख/Date Of Hearing : 05.06.2025 घोषणा की तारीख /Date Of Pronouncement : 07.07.2025

charitable Trust. There was a search u/s.132 of the Act on 20.01.2021 in the case of the Assessee and it’s associate M/s.Jesus Calls. During the search various books of accounts, loose sheets / electronic devices found and seized. 4. The Assessee had used software named as ‘Campus Management System’ (CMS) developed by Dimensions Innovations Lab, Kerala in the early years

KARUNYA EDUCATIONAL AND RESEARCH TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(1), CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकरअपील सं./Ita Nos.799/Chny/2025, Assessment Year: 2017-18 आयकरअपील सं./Ita Nos.800/Chny/2025, Assessment Year: 2018-19 आयकरअपील सं./Ita Nos.801/Chny/2025, Assessment Year: 2019-20 आयकरअपील सं./Ita Nos.802/Chny/2025, Assessment Year: 2020-21 आयकरअपील सं./Ita Nos.803/Chny/2025, Assessment Year: 2021-22 Karunya Educational & Vs. Deputy Commissioner Of Income Tax, Research Trust, Central Circle-3(1), No.16, Dr.D.G.S.Dhinakaran Road, Chennai. Raja Annamalaipuram, Chennai-600 028. [Pan:Aaatk0225H] (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. V.Nagaprasad, Advocate & Ms.S.Revathy, F.C.A. प्रत्यर्थी की ओर से /Respondent By : Mr. M.K.Biju, Cit Dr सुनवाई की तारीख/Date Of Hearing : 05.06.2025 घोषणा की तारीख /Date Of Pronouncement : 07.07.2025

charitable Trust. There was a search u/s.132 of the Act on 20.01.2021 in the case of the Assessee and it’s associate M/s.Jesus Calls. During the search various books of accounts, loose sheets / electronic devices found and seized. 4. The Assessee had used software named as ‘Campus Management System’ (CMS) developed by Dimensions Innovations Lab, Kerala in the early years

M.PALANISAMY ,COIMBATORE vs. ACIT NON CORPORATE CIRCLE 2 , COIMBATORE

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri G. Manjunatha

section 40A(2)(a) of the Income tax Act, 1961. 4. The Ld. CIT(A) has failed to appreciate that the lease rent fixed by the concerns is purely an arrangement to avoid the income component in the hands of the assessee. 5. For these and other grounds, that may be adduced at the time of hearing, the order

ACIT NON CORP CIRCLE 2 , COIMBATORE vs. M.PALANISAMY, COIMBATORE

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri G. Manjunatha

section 40A(2)(a) of the Income tax Act, 1961. 4. The Ld. CIT(A) has failed to appreciate that the lease rent fixed by the concerns is purely an arrangement to avoid the income component in the hands of the assessee. 5. For these and other grounds, that may be adduced at the time of hearing, the order

ACIT NON CORP CIRCLE 2 , COIMBATORE vs. M.PALANISAMY, COIMBATORE

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri G. Manjunatha

section 40A(2)(a) of the Income tax Act, 1961. 4. The Ld. CIT(A) has failed to appreciate that the lease rent fixed by the concerns is purely an arrangement to avoid the income component in the hands of the assessee. 5. For these and other grounds, that may be adduced at the time of hearing, the order

BANNARIAMMAN EDUCATIONAL TRUST,COIMBATORE vs. ACIT CENTRAL CIRCLE 3(2), CHENNAI

Trust Group, Tiruvannamalai through Mr. Yegappan. The Ld. \nAR pointed out that, even in this answer, he was not clear as to whom did \nthis single noting of Rs.11,99,000/- pertain to. The Ld. AR brought to our \nnotice that thereafter, a leading question (Q No. 34) was put forth by the \nInvestigating Officer to Shri Muthu, in which

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

charitable trusts where the investors name and beneficial interest are not explicitly known on the date of its creation- such information becoming available only when the funds starts accepting contribution from the investors, have to be treated as falling within Sec.164(1) of the Act and the fund should be taxed in respect of the income received on behalf

ITO, CHENNAI vs. TVS SHRIRAM GROWTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

charitable trusts where the investors name and beneficial interest are not explicitly known on the date of its creation- such information becoming available only when the funds starts accepting contribution from the investors, have to be treated as falling within Sec.164(1) of the Act and the fund should be taxed in respect of the income received on behalf

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

charitable trusts where the investors name and beneficial interest are not explicitly known on the date of its creation- such information becoming available only when the funds starts accepting contribution from the investors, have to be treated as falling within Sec.164(1) of the Act and the fund should be taxed in respect of the income received on behalf

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

charitable trusts where the investors name and beneficial interest are not explicitly known on the date of its creation- such information becoming available only when the funds starts accepting contribution from the investors, have to be treated as falling within Sec.164(1) of the Act and the fund should be taxed in respect of the income received on behalf

ITO, CHENNAI vs. TVS SHRIRAM GRWOTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

charitable trusts where the investors name and beneficial interest are not explicitly known on the date of its creation- such information becoming available only when the funds starts accepting contribution from the investors, have to be treated as falling within Sec.164(1) of the Act and the fund should be taxed in respect of the income received on behalf

CHINNA PONNU AMMAL TRUST,VILLUPURAM vs. DCIT , CPC, BANGALORE

The appeal stands allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

2. The Ld. AR, drawing attention to the computation of income and income as computed by CPC, submitted that Explanation 3 to Sec.11(1) has not been applied correctly and demand has been raised erroneously. The Ld. Sr. DR submitted that the return has been processed by CPC as filed by the assessee which has already been noted

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

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

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