M/S J SIKILE FOUNDATION,CHENNAI vs. DCIT, EXEMPTION-III, CHENNAI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.83/Chny/2022 िनधा"रणवष"/Assessment Year: 2011-12 V. M/S.J Sikile Foundation, The Dcit, Plot No.1025, Street No.44, Exemption-Iii, Tvs Colony, Anna Nagar West Extn., Chennai. Chennai-600 101. [Pan: Aaats 1630 C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Charitable Trust; and that during the initial/formative years, M/s.SIPL used to support the assessee-foundation to establish the Educational Institutions which fact is corroborated/reflected in the ledger account of the said company (M/s.SIPL) in the books of the assessee right from 1984-85. It was submitted that it was maintaining running-account between them [assessee-foundation and M/s.SIPL] and pleaded

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

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

54 assessment order must be erroneous and secondly, it must be prejudicial to the interests of the Revenue. Further, Explanation 2 to Section 263 of the Act delineates certain conditions and circumstances when the order passed by the AO can be said to be erroneous and prejudicial to the Revenue. 20. Clause (a) of Explanation 2 to Section

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.

54 assessment order must be erroneous and secondly, it must be prejudicial to the interests of the Revenue. Further, Explanation 2 to Section 263 of the Act delineates certain conditions and circumstances when the order passed by the AO can be said to be erroneous and prejudicial to the Revenue. 20. Clause (a) of Explanation 2 to Section

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.

54 assessment order must be erroneous and secondly, it must be prejudicial to the interests of the Revenue. Further, Explanation 2 to Section 263 of the Act delineates certain conditions and circumstances when the order passed by the AO can be said to be erroneous and prejudicial to the Revenue. 20. Clause (a) of Explanation 2 to Section

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

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

54 any activity in the nature, trade, commerce or bus/ness or any activity of rendering in services in relation to trade, commerce or business. Therefore, the exemption is not available in view of adding of proviso to section 15 particularly the 4th limbs definition of the charitable purpose. We find that the assessee did not lend loans to beneficiaries directly

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. EVERWIN EDUCATIONAL AND CHARITABLE TRUST, KOLATHUR, CHENNAI

In the result, appeal filed by the Revenue is dismissed

charitable trust with additional costs. The AO however not agreeable to the explanation furnished by the assessee and held that the act of registration of property in the individual names of the trustees was a clear violation of Section 13(1)(c) of the Act as a benefit accrued to the trustees because the legal ownership was with them

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

THE WILLINGDON CHARITABLE TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

THE WILLINGDON CHARITABLE TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

DCIT, CHENNAI vs. M/S. WILLINGDON CHARITABLE TRUST, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

THE WILLINGDON CHARITABLE TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

THE WILLINGDON CHARITABLE TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

THE WILLINGDON CHARITABLE TRUST,CHENNAI vs. DDIT, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with

THE WILLINGDON CHARITABLE TRUST,CHENNAI vs. DDIT, CHENNAI

In the result, both the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

trust which has similar object and approved under Section 80G of the Act, from and out of current profit, this Tribunal is of the considered opinion 24 I.T.A. Nos.2984 to 2988/Chny/16 I.T.A. Nos.3021 to 3026/Chny/16 that the assessee is eligible for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any reason to interfere with