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

trust deed, amendment deed, audited books of account for FY 2013-14 (AY 2014-15) were furnished vide Annexure I and soft copy respectively in response to the question Nos. 1 & 5 of the questionnaire issued under section 142(1) of the Act. Further, it is noted that the assessee replied that no assets acquired during the year under consideration

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

trust deed, amendment deed, audited books of account for FY 2013-14 (AY 2014-15) were furnished vide Annexure I and soft copy respectively in response to the question Nos. 1 & 5 of the questionnaire issued under section 142(1) of the Act. Further, it is noted that the assessee replied that no assets acquired during the year under consideration

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

sections of the society. The Ld.AO has not substantiated his findings, that the work of the trust is not charitable and the interest charged by the assessee does not commensurate with the cost incurred by it. The Ld.AO placed nothing on record to show that the assessee is charging exorbitant interest. The action of the Ld.AO might have justified

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

ITO(EXCEMPTION) TRICHY, TRICHY vs. GRAMA VIDIYAL TRUST, TRICHY

In the result, both ITA No

Bench: Shri Veeravalli Durga Rao, Jm & Shri Girish Agrawalita Nos.1534 & 1535/Chny/2019 Assessment Years: 2009-10 & 2011-12 Income-Tax Officer, Grama Vidiyal Trust, (Exemptions), Trichy Vs. No. 44, Williams Road, Cantonment, Trichy-620001 (Pan: Aaatg2928F) (Appellant) (Respondent) Present For: Appellant By : Shri N. V. Balaji, Advocate Respondent By : Shri Arv. Sreenivasan, Addl. Cit Date Of Hearing : 31.05.2022 Date Of Pronouncement : 24.08.2022 O R D E R Per Girish Agrawal: Both These Appeals By Revenue Are Directed Against The Separate Orders Of Ld. Cit(A)-1, Trichy Vide Ita No. 156/2017-18/Cit(A)-1/Try Dated 04.03.2019 & 163/2017-18/Cit(A)-1/Try Dated 22.02.2019 Against The Separate Orders Of Ld. Ito, Exemptions Ward, Trichy, Passed U/S 143(3) R.W.S. 254 Of The Income-Tax Act,1961 (Hereinafter Referred To As The Act), Both Dated 30.12.2017 For Ays 2009-10 & 2011-12. 2. First We Take Up Ita No. 1534/Chny/2019 For Ay 2009-10 For Which The Revised Ground Taken By The Revenue Is As Under:

charitable trust to plead that taxation of trust has to be done purely as per the law and that section 11A was fully applicable to the trust as micro finance activity was no longer part of the trust, and hence benefit of above mentioned cases had to be given to the assessee.” 11.3. Accordingly, limiting our finding on the issue

ITO(EXCEMPTION) TRICHY, TRICHY vs. GRAMA VIDIYAL TRUST, TRICHY

In the result, both ITA No

Bench: Shri Veeravalli Durga Rao, Jm & Shri Girish Agrawalita Nos.1534 & 1535/Chny/2019 Assessment Years: 2009-10 & 2011-12 Income-Tax Officer, Grama Vidiyal Trust, (Exemptions), Trichy Vs. No. 44, Williams Road, Cantonment, Trichy-620001 (Pan: Aaatg2928F) (Appellant) (Respondent) Present For: Appellant By : Shri N. V. Balaji, Advocate Respondent By : Shri Arv. Sreenivasan, Addl. Cit Date Of Hearing : 31.05.2022 Date Of Pronouncement : 24.08.2022 O R D E R Per Girish Agrawal: Both These Appeals By Revenue Are Directed Against The Separate Orders Of Ld. Cit(A)-1, Trichy Vide Ita No. 156/2017-18/Cit(A)-1/Try Dated 04.03.2019 & 163/2017-18/Cit(A)-1/Try Dated 22.02.2019 Against The Separate Orders Of Ld. Ito, Exemptions Ward, Trichy, Passed U/S 143(3) R.W.S. 254 Of The Income-Tax Act,1961 (Hereinafter Referred To As The Act), Both Dated 30.12.2017 For Ays 2009-10 & 2011-12. 2. First We Take Up Ita No. 1534/Chny/2019 For Ay 2009-10 For Which The Revised Ground Taken By The Revenue Is As Under:

charitable trust to plead that taxation of trust has to be done purely as per the law and that section 11A was fully applicable to the trust as micro finance activity was no longer part of the trust, and hence benefit of above mentioned cases had to be given to the assessee.” 11.3. Accordingly, limiting our finding on the issue

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)

70% of revenues to member cricket associations, including the assessee-society. The Ld. representative has clarified that the assessee earns income under the following heads:- (1) Subscription from members (2) Sale of tickets (3) Revenue from advertisements (4) Receipts from BCCI (5) Interest from bank deposits According to the Ld. representative, the assessee-society in fact uses all these incomes

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)

70% of revenues to member cricket associations, including the assessee-society. The Ld. representative has clarified that the assessee earns income under the following heads:- (1) Subscription from members (2) Sale of tickets (3) Revenue from advertisements (4) Receipts from BCCI (5) Interest from bank deposits According to the Ld. representative, the assessee-society in fact uses all these incomes

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)

70% of revenues to member cricket associations, including the assessee-society. The Ld. representative has clarified that the assessee earns income under the following heads:- (1) Subscription from members (2) Sale of tickets (3) Revenue from advertisements (4) Receipts from BCCI (5) Interest from bank deposits According to the Ld. representative, the assessee-society in fact uses all these incomes

M/S AVM CHARITIES ,CHENNAI vs. ITO,EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

70,707/- as income of the appellant by invoking provisions of section 13(1)(c) r.w.s.13(2) of the Act and in consequently erred in levying tax at maximum marginal rate as per Proviso to Section 164(2) of the Act. 11. For that the Learned Commissioner of Income Tax (Appeals) erred in confirming the action of Assessing Officer

M/S. A V M CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

70,707/- as income of the appellant by invoking provisions of section 13(1)(c) r.w.s.13(2) of the Act and in consequently erred in levying tax at maximum marginal rate as per Proviso to Section 164(2) of the Act. 11. For that the Learned Commissioner of Income Tax (Appeals) erred in confirming the action of Assessing Officer

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

70,707/- as income of the appellant by invoking provisions of section 13(1)(c) r.w.s.13(2) of the Act and in consequently erred in levying tax at maximum marginal rate as per Proviso to Section 164(2) of the Act. 11. For that the Learned Commissioner of Income Tax (Appeals) erred in confirming the action of Assessing Officer

M/S AVM CHARITIES,CHENNAI vs. ITO,EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

70,707/- as income of the appellant by invoking provisions of section 13(1)(c) r.w.s.13(2) of the Act and in consequently erred in levying tax at maximum marginal rate as per Proviso to Section 164(2) of the Act. 11. For that the Learned Commissioner of Income Tax (Appeals) erred in confirming the action of Assessing Officer

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

70,707/- as income of the appellant by invoking provisions of section 13(1)(c) r.w.s.13(2) of the Act and in consequently erred in levying tax at maximum marginal rate as per Proviso to Section 164(2) of the Act. 11. For that the Learned Commissioner of Income Tax (Appeals) erred in confirming the action of Assessing Officer

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

70,707/- as income of the appellant by invoking provisions of section 13(1)(c) r.w.s.13(2) of the Act and in consequently erred in levying tax at maximum marginal rate as per Proviso to Section 164(2) of the Act. 11. For that the Learned Commissioner of Income Tax (Appeals) erred in confirming the action of Assessing Officer

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

70,707/- as income of the appellant by invoking provisions of section 13(1)(c) r.w.s.13(2) of the Act and in consequently erred in levying tax at maximum marginal rate as per Proviso to Section 164(2) of the Act. 11. For that the Learned Commissioner of Income Tax (Appeals) erred in confirming the action of Assessing Officer

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

70,10,350 2006-07 14,04,38,300 1,62,62,700 2007-08 17,96,60,001 3,92,21,701 2008-09 29,22,25,001 11,25,65,000 ITA Nos2125 to 2128 :- 4 -: & 2219 to 2222 /2017 (iv) A large number of parents had confirmed that donations paid by them were nothing but capitation

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

70,10,350 2006-07 14,04,38,300 1,62,62,700 2007-08 17,96,60,001 3,92,21,701 2008-09 29,22,25,001 11,25,65,000 ITA Nos2125 to 2128 :- 4 -: & 2219 to 2222 /2017 (iv) A large number of parents had confirmed that donations paid by them were nothing but capitation