M/S ALPHA EDUCATIONAL TRUST ,CHENNAI vs. DCIT (EXEMPTIONS), CHENNAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Mahavir Singh, Vice-आयकरअपीलसं./I.T.A.No.588/Chny/2022 ("नधा"रणवष" / Assessment Year: 2011-12) M/S. Alpha Educational Trust Vs The Dcit (Exemptions), No.2/310, Jeeva Street, Chennai. Mondiamman Nagar, Red Hills, Chennai-600 052. Pan: Aacta 9230A (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 12A of the I.T. Act are not applicable in the instant case and the appellant's reliance on these notes are misplaced and not relevant. 5.7 In view of the clear judgement of the Supreme Honourable 4 Court in the case of UP Forest Corporation (2007) 165 taxmann 533(SC), in which it held that registration is a condition

M/S. SUSILA EDUCATIONAL TRUST,,VILLUPURAM vs. ITO (EXEMPTIONS), WARD-1,, CHENNAI

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

disallowed the exemption, stating that the return was filed beyond the time limit prescribed under Section 139(1) of the Act. The CIT(A) upheld the AO's decision.", "held": "The Tribunal held that the CBDT's clarification, specifically Circular No.2/2018 and subsequent communication dated 23.04.2019, indicates that a return filed under Section 139(4) (belatedly) is to be considered

C.R.ANAND EDUCATIONAL TRUST,MADURAI vs. ITO, EXEMPTION, MADURAI

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri C.M. Garg, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.2802/Chny/2019 (धििाारण वर्ा / Assessment Year : 2009-10) C.R. Anand Educational Trust, V Ito, Exemption, Madurai. No. 34, Ganeshapuram, S K. Pudur, Madurai – 625 007. Pan No. : Aabtc1675J (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्ाारिती की ओर से /Assessee By : Shri S. Sankaralingam, Cit (Rtd) & Shri B. Gopalakrishnan, Advocate Ar िाजस्व की ओर से /Revenue By : Shri G. Johnson, Addl. Cit Dr सुिवाई की तािीख / Date Of Hearing : 15/02/2022 घोषणा की तािीख/Date Of Pronouncement : 22/02/2022 आदेश / O R D E R Per Arun Khodpia, Am:

Section 12A(2) of the Act is applicable to the present case. 8. Having heard to the rival parties and considering the relevant materials available on record, we find in the instant case that the assessee trust was created on 02.12.2008. Its first assessment was done by Ld. AO u/s. 148 on 18.07.2011, however, while passing the re-assessment

THE CRAFTS COUNCIL OF INDIA,CHENNAI vs. JCIT(EXEMPTIONS), CHENNAI

12A ofthe Act being an\norganization established with the objects of charitable purpose. For the relevant\n Assessment year, the appellant filed its return of Income disclosing NIL income.\nDuring the assessment u/s 143(3) of the Income Tax Act, the Joint\nCommissioner of Income Tax (JCIT) invoked proviso to section 2(15) in respect\nof certain income which

INCOMETAX OFFICER EXEMPTIONS WARD, TIRUNELVELI vs. THE CHRISTIAN BUSINESSMEN EDUCATIONAL FELLOWSHIP, KOVILPATTI

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./ Ita No.2395/Chny/2025 "नधा"रण वष" /Assessment Year: 2019-20 The Income Tax Officer, The Christian Businessmen Exemptions Ward Vs. Educational Fellowship, Nellai City Centre, Rahmath Nagar, No.46, Alwar Street, Tiruchendur Road, Kovilpatti, Tirunelvali, Tamil Nadu-628501 Tamil Nadu-627011 [Pan: Aacat2359N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr.C.Sivakumar, Addl.Cit ""यथ" क" ओर से /Respondent By : Mr.R. Viswanthan, Ca सुनवाई क" तार"ख/Date Of Hearing : 07.01.2026 घोषणा क" तार"ख /Date Of Pronouncement : 19.01.2026

12A and the application of income under section 11 cannot be examined or disallowed at :- 4 -: the stage of section

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

disallow exemption under section\n11 of the Act to assume jurisdiction to reopen the assessment. He argued\nthat in the case of Songwoon Speciality Chemicals India (P.) Ltd. v. DCIT\n[2024] 169 taxmann.com 184 (Gujarat), when the claim was accepted in\nthe original assessment proceedings and the Assessing Officer could not\nhave reopened assessment on the same facts which

M/S. AURO LAB TRUST,,MADURAI vs. ITO, MADURAI

In the result, all the appeals filed by the assessee are partly\nallowed

section 11 and 12 will not apply in the absence of\nregistration u/s. 12A, then this amount of Rs.11,65,89,634/ - cannot\nbe brought to tax in the Asst. Year 2011-12.\n8. For these and such other grounds that may be permitted to be\nraised during the For Aurolab Trust hearing of the appeal.”\n3. Ground No.1

GOOD SHEPHERD HOLISTIC EDUCATIONAL TRUST,TRICHY vs. ITO, WARD-1(1), TRICHY

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

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.:3105/Chny/2024 िनधा"रण वष"/Assessment Year:2018-19 Good Shepherd Holistic The Income Tax Officer, Educational Trust, Vs. Ward 1(1), Plot No.452, Usman Ali Nagar, Trichy. Kk Nagar, Trichy – 620 021. Pan: Aactg 1957E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Ms. Sita Krishnamoorthy, Jcit सुनवाई क" तारीख/Date Of Hearing : 10.06.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.06.2025

disallowed the Capital Expenditure and donation expenditure claimed as deduction u/s section 57. Further the contention of the assessee with regard to the applicability of Section 12A

HARI FOUNDATION,COIMBATORE vs. DLC-CA-(211)(1), ACIT EXEMPTIONS, COIMBATORE

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

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.917/Chny/2024 िनधा"रणवष"/Assessment Year: 2020-21 V. Hari Foundation, The Acit (Exemptions), 3-1, Indira Nagar, Coimbatore. Kuniamuthur S.O., Coimbatore-641 035. [Pan: Aabth 2056 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowed the exemption u/s.11 of the Act alleging failure on the part of the assessee to file the Audit Report of the accounts of the Trust (Form 10B) within due time which in this case was 15.02.2021 and the assessee belatedly filed the same within ‘32’ days on 20.03.2021 (refer rectification order u/s.154 of the CPC). According to the Ld.AR

ST. FRANCIS EDUCATIONAL TRUST,,CHENNAI vs. ITO, EXEMPTION WARD-2,, CHENNAI

In the result, the appeal filed by assessee in ITA No

Bench: Shri Ramit Kochar & Shri Duvvuru R.L.Reddy

disallowed the exemption claimed under section 11 of the Act. 2.3 The Learned AO has erred in invoking the provisions of Section 13(1)(c) of the Act without a holistic understanding of the facts of the case”. 6.3 In the written submission, the appellant contested that the trust had obtained term loan based on the collateral security

ANDHRA SOCIAL & CULTURAL ASSOCIATION,CHENNAI vs. ACIT NON CORPORATE CIRCLE 1, CHENNAI

In the result, all the five appeals filed by the assessee stand

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

disallowed the claim of the assessee and also levied penalty under Section 271(1)(c) of the Act. The Ld. representative placed his reliance on various judgments of High Courts and Apex Court and submitted that the penalty under Section 271(1)(c) of the Act cannot be levied unless there was concealment of income or furnishing of inaccurate particulars

ANDHRA SOCIAL & CULTURAL ASSOCIATION,CHENNAI vs. ACIT NON CORPORATE CIRCLE 1, CHENNAI

In the result, all the five appeals filed by the assessee stand

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

disallowed the claim of the assessee and also levied penalty under Section 271(1)(c) of the Act. The Ld. representative placed his reliance on various judgments of High Courts and Apex Court and submitted that the penalty under Section 271(1)(c) of the Act cannot be levied unless there was concealment of income or furnishing of inaccurate particulars

ANDHRA SOCIAL & CULTURAL ASSOCIATION,CHENNAI vs. ACIT NON CORPORATE CIRCLE 1, CHENNAI

In the result, all the five appeals filed by the assessee stand

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

disallowed the claim of the assessee and also levied penalty under Section 271(1)(c) of the Act. The Ld. representative placed his reliance on various judgments of High Courts and Apex Court and submitted that the penalty under Section 271(1)(c) of the Act cannot be levied unless there was concealment of income or furnishing of inaccurate particulars

ANDHRA SOCIAL & CULTURAL ASSOCIATION,CHENNAI vs. ACIT NON CORPORATE CIRCLE 1, CHENNAI

In the result, all the five appeals filed by the assessee stand

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

disallowed the claim of the assessee and also levied penalty under Section 271(1)(c) of the Act. The Ld. representative placed his reliance on various judgments of High Courts and Apex Court and submitted that the penalty under Section 271(1)(c) of the Act cannot be levied unless there was concealment of income or furnishing of inaccurate particulars

ANDHRA SOCIAL & CULTURAL ASSOCIATION,CHENNAI vs. ACIT NON CORPORATE CIRCLE 1, CHENNAI

In the result, all the five appeals filed by the assessee stand

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

disallowed the claim of the assessee and also levied penalty under Section 271(1)(c) of the Act. The Ld. representative placed his reliance on various judgments of High Courts and Apex Court and submitted that the penalty under Section 271(1)(c) of the Act cannot be levied unless there was concealment of income or furnishing of inaccurate particulars

KM EDUCATIONAL AND RURAL DEVELOPMENT TRUST,VEMBAKOTTAI vs. ITO, EXEMPTIONS, MADURAI

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

Bench: Shri Aby T. Varkey & Shri Jagadish

section 12A registration and filed its Return of Income [RoI] for AY 2018- 19 belatedly on 30.11.2018 declaring total income of Rs.NIL and claimed refund of Rs.1,96,656/-. However, the CPC while processing the return u/s.143(1) of the Act on 30.09.2019 computed the total income at Rs.2,14,33,895/- and raised demand of Rs.92,83,542/- instead

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 :

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

ARUTPERUM JOTHI ARAKKATTALAI,SALEM vs. ITO, EXEMPTION WARD., SALEM

In the result, the appeal of the assessee is allowed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI JAGADISH (Accountant Member)

disallow the appellant's claim for exemption under Section 11 and 12 of the Act when processing the return under Section 143(1) of the Act. Further, the ld. Departmental Representative also vehemently submitted that according to the Provisions of Section 44AB of the Act, as per explanation (ii) the specified date means, the date of one month prior

SHRIRAM FINANCE LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE 3(1), CHENNAI, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.173/Chny/2024 िनधा"रण वष"/Assessment Year: 2020-21 Shriram Finance Limited Vs. The Deputy Commissioner Of [Formerly Known As Shriram Transport Income Tax, Finance Company Limited), Corporate Circle 3(1), Sri Towers, Plot No. 14A, South Phase, Chennai. Industrial Estate, Guindy, Chennai 600 017. [Pan: Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri R.V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.07.2024 घोषणा की तारीख /Date Of Pronouncement : 09.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.11.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21. 2. Ground No. 1 Is General In Nature & Requires No Adjudication.

disallowances taking into account the same income as made under section 143(1) of the Act by separate order passed under section 143(3) of the Act. The assessee preferred separate appeal against the said order passed under section 143(3) of the Act. The contention of the ld. AR is that once scrutiny assessment proceedings is taken