THE THANTHI TRUST,CHENNAI vs. JCIT, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Section 2(15), which defines ‘charitable purpose’. Such attempt is wholly unsustainable and impermissible under law. The Revenue is estopped both on law as well as on facts from raising any contention as mentioned by the DIT(E) in its order dated 08.12.2011. The said order is an outcome of wrong understanding of the legal provisions, the effect

THE THANTHI TRUST,CHENNAI vs. JCIT, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Section 2(15), which defines ‘charitable purpose’. Such attempt is wholly unsustainable and impermissible under law. The Revenue is estopped both on law as well as on facts from raising any contention as mentioned by the DIT(E) in its order dated 08.12.2011. The said order is an outcome of wrong understanding of the legal provisions, the effect

THE THANTHI TRUST,CHENNAI vs. JCIT, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Section 2(15), which defines ‘charitable purpose’. Such attempt is wholly unsustainable and impermissible under law. The Revenue is estopped both on law as well as on facts from raising any contention as mentioned by the DIT(E) in its order dated 08.12.2011. The said order is an outcome of wrong understanding of the legal provisions, the effect

THE THANTHI TRUST,CHENNAI vs. ADIT (EXEMPTIONS) , CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Section 2(15), which defines ‘charitable purpose’. Such attempt is wholly unsustainable and impermissible under law. The Revenue is estopped both on law as well as on facts from raising any contention as mentioned by the DIT(E) in its order dated 08.12.2011. The said order is an outcome of wrong understanding of the legal provisions, the effect

M.P. SANTHOSH KUMAR, ITO, CHENNAI vs. GREENPEACE ENVIRONMENT TRUST, CHENNAI

In the result, appeal filed by the Revenue stands dismissed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 406/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2011-12 Income Tax Officer, Greenpeace Environment Trust, Exemptions, Ward-1, Vs. New No.49, Old No.23, Chennai. Ellaiamman Colony, Gopalapuram, Chennai-600 086. [Pan:Aaatg-3538-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. Kumar Chandan, Jcit. प्रत्यथी की ओर से/Respondent By : Shri. Y.Sridhar, F.C.A. सुनवाई की तारीख/Date Of Hearing : 19.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 25.08.2025 आदेश /O R D E R Per S. R. Raghunatha, Am :

charitable institutions registered under section 12A of the Act having similar objects was not in violation of the provisions of section 13(1)(d) read with section 11(5) of the Act. Where the Assessing Officer disallowed the depreciation while working out the application of income in relation to purposes of the assessee-trust in terms of section

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

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

45-46 of the\nConstitution of India.\nB. The Trust is collecting fees for conducting unorganized\ncourses which is its major source of income and booking the\nsame in its accounts as sale of service and this falls in the\ncategory of business in the nature of trade, commerce, etc.,\nwith profit motive and cannot be held as charitable

DDIT, CHENNAI vs. VELS INSTITUTE OF SCIENCE, TECHNOLOGY & ADVANCED STUDIES,, CHENNAI

In the result, both the appeal of the Revenue and the cross- objection of the assessee stand dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1759/Mds/2013 & C.O. No.15/Mds/2014 (In I.T.A. No.1759/Mds/2013) "नधा"रण वष" / Assessment Year : 2010-11

Trust is registered as charitable institution and it is claiming exemption under Section 11 of the Act. The claim of the assessee under Section 11 of the Act is allowed by the CIT(Appeals) which was confirmed by this Tribunal in the earlier part of this order. It is not the case of the assessee that it is not doing

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

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

45-46 of the\nConstitution of India.\nB. The Trust is collecting fees for conducting unorganized\ncourses which is its major source of income and booking the\nsame in its accounts as sale of service and this falls in the\ncategory of business in the nature of trade, commerce, etc.,\nwith profit motive and cannot be held as charitable

DEPUTY COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE, CHENNAI, INCOME TAX DEPARTMENT vs. THE INDIAN INSTITUTE OF ENGINEERING TECHNOLOGY, CHENNAI

In the result the appeal of the Revenue dismissed

Bench: Shri Mahavir Singh & Shri S.R. Raghunathaआयकर अपील सं./Ita No.679/Chny/2024 िनधा;रण वष; /Assessment Year: 2012-13 The Dy. Commissioner Of The Indian Institute Of Engineering Income Tax, Vs. Technology, Exemptions Circle, 363, Arcot Road, Kodambakkam, Chennai. Chennai – 600 024. [Pan: Aaatt 2768C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथH की ओर से/ Assessee By : Shri R. Vijayaraghavan, Advocate JkथH की ओर से /Revenue By : Shri N. Sanjay Gandhi, Jcit सुनवाई की तारीख/Date Of Hearing : 11.06.2024 घोषणा की तारीख /Date Of Pronouncement : 30.08.2024 आदेश / O R D E R Per S.R. Raghunatha, A.M : This Appeal By The Revenue Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), (Nfac), Delhi [Hereinafter “Cit(A)] In Din & Order No.Itba/Nfac/S/250/2023- 24/1059500064(1), Dated 09.01.2024. The Assessment Was Framed By The Assessing Officer For The Assessment Year 2012-13 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’), Vide Order Dated 20.03.2015. :- 2 -: 2. There Is A Delay Of 06 Days In Filing The Appeal By The Revenue.

charitable trust, registered U/s.12AA of the Act, vide DIT(E) No.2(41)/91-92 dated 29/06/1993. The assessee trust is created to establish institutions for studies and research for the advancement of knowledge, skill, training and education for every kind including technology, engineering and professional studies and to construct and acquire building, structures, equipments, implements whatsoever necessary for the purpose. Towards

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

Charitable Trust and CT Scan, MRI Scan &\nUSC fees shown by the company in its P & L account for the A.Υ. 2012-13 to\nAY 2017-18. The same is tabulated as below:\nSL No\nAY\nTotal fees receipts\nmade out of CT\nscan, MRI scan and\nUltra sound machine\nby the Company (in\nRs.)\nCT scan\nfees\ntransferred

DCIT, CHENNAI vs. M/S. TAMIL NADU CRICKET ASSOCIATION, CHENNAI

In the result, both the appeals of the Revenue as well as the cross-objections of the assessee are dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita Nos.2556 & 2557/Mds/2016 & C.O. Nos.158 & 159/Mds/2016 (In Ita Nos.2556 & 2557/Mds/2016) "नधा"रण वष" / Assessment Years : 2011-12 & 2012-13

trust claiming exemption under section 11(1) of the Income- tax Act, 1961, must spend at least 75 per cent of its total income, for religious or charitable purposes. In other words, it was not permitted to accumulate more than 25 per cent of its total income. The question has been reconsidered by the Board and the correct legal position

DCIT, CHENNAI vs. M/S. TAMIL NADU CRICKET ASSOCIATION, CHENNAI

In the result, both the appeals of the Revenue as well as the cross-objections of the assessee are dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita Nos.2556 & 2557/Mds/2016 & C.O. Nos.158 & 159/Mds/2016 (In Ita Nos.2556 & 2557/Mds/2016) "नधा"रण वष" / Assessment Years : 2011-12 & 2012-13

trust claiming exemption under section 11(1) of the Income- tax Act, 1961, must spend at least 75 per cent of its total income, for religious or charitable purposes. In other words, it was not permitted to accumulate more than 25 per cent of its total income. The question has been reconsidered by the Board and the correct legal position

DDIT, CHENNAI vs. THE BOOKSELLERS & PUBLISHERS ASSOCIATION OF SOUTH INDIA, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1602/Mds/2014 "नधा"रण वष" / Assessment Year : 2009-10 M/S The Booksellers & Publishers The Deputy Director Of Income Association Of South India, No.8, Sun Plaza, 2Nd Floor, Tax (Exemptions) – I, V. Chennai - 600 034. G.N. Chetty Road, T. Nagar, Chennai - 600 006. Pan : Aabta 2098 R (अपीलाथ"/Appellant) (""यथ"/Respondent)

trust claiming exemption under section 11(1) of the Income- tax Act, 1961, must spend at least 75 per cent of its total income, for religious or charitable purposes. In other words, it was not permitted to accumulate more than 25 per cent of its total income. The question has been reconsidered by the Board and the correct legal position

ST.JOSEPH'S EDUCATIONAL TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

45,31,350 6,80,65,000 Science and Technology Trust St. Joseph Education Trust 2020-21 24,00,000 78,75,000 1,02,75,000 sheet as 'cash' were offered to tax "anonymous donations" and paid taxes thereon under section 115BBC of the Act. The seized material Ann/JCE/ANJ/ED/S-1 does not mention that the alleged receipts are capitation fees

ST.JOSEPH'S INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

45,31,350 6,80,65,000 Science and Technology Trust St. Joseph Education Trust 2020-21 24,00,000 78,75,000 1,02,75,000 sheet as 'cash' were offered to tax "anonymous donations" and paid taxes thereon under section 115BBC of the Act. The seized material Ann/JCE/ANJ/ED/S-1 does not mention that the alleged receipts are capitation fees

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

section 2(15) of the Act as activity of sale of land was incidental to objects of Trust and said profit had been applied for objects of Trust. 44 I.T.A. Nos.1667 to 1670/Chny/24 50. In the present case, as we have discussed above in the aforementioned paragraphs, the assessee was contending after the discontinuation of its Teachers Education College which

TAMIL NADU CRICKET ASSOCIATION,CHENNAI vs. DDIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1535, 1536 & 1537/Mds/2014 "नधा"रण वष" / Assessment Years : 2008-09 To 2010-11 M/S Tamil Nadu Cricket Association, The Deputy Director Of No.5, M.A.Chidambaram Stadium, V. Income Tax (Exemptions), Victoria Hostel Road, Chennai - 600 034. Chepauk, Chennai - 600 005. Pan : Aaaat 0398 M (अपीलाथ"/Appellant) (""यथ"/Respondent)

trust claiming exemption under section 11(1) of the Income- tax Act, 1961, must spend at least 75 per cent of its total income, for religious or charitable purposes. In other words, it was not permitted to 17 I.T.A. Nos.1535 to 1537/Mds/14 accumulate more than 25 per cent of its total income. The question has been reconsidered by the Board

TAMIL NADU CRICKET ASSOCIATION,CHENNAI vs. DDIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1535, 1536 & 1537/Mds/2014 "नधा"रण वष" / Assessment Years : 2008-09 To 2010-11 M/S Tamil Nadu Cricket Association, The Deputy Director Of No.5, M.A.Chidambaram Stadium, V. Income Tax (Exemptions), Victoria Hostel Road, Chennai - 600 034. Chepauk, Chennai - 600 005. Pan : Aaaat 0398 M (अपीलाथ"/Appellant) (""यथ"/Respondent)

trust claiming exemption under section 11(1) of the Income- tax Act, 1961, must spend at least 75 per cent of its total income, for religious or charitable purposes. In other words, it was not permitted to 17 I.T.A. Nos.1535 to 1537/Mds/14 accumulate more than 25 per cent of its total income. The question has been reconsidered by the Board