KAUMARA MADALAYAM,COIMBATORE vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), COIMBATORE, COIMBATORE

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri S.R. Raghunathaआयकर अपील सं./Ita No.680/Chny/2024 िनधा:रण वष: /Assessment Year: 2015-16 Kaumara Madalayam, The Dy. Commissioner Of Income Chinnavedampatti Post, Vs. Tax (Exemptions), Coimbatore – 641 049. Coimbatore. [Pan: Aabtk 6034B]. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथG की ओर से/ Assessee By : Shri N.V. Krishnan, Advocate IjथG की ओर से /Revenue By : Shri N. Sanjay Gandhi, Jcit सुनवाई की तारीख/Date Of Hearing : 13.06.2024 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 Assessee 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/250/2023-24/1059915043(1), Dated 19.01.2024. The Assessment Was Framed By The Dy. Commissioner Of Income Tax (Exemptions), Coimbatore For The Assessment Year 2015-16 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’), Vide Order Dated 12.12.2017. :- 2 -: 2. The Assessee Has Raised The Following Grounds Of Appeal:

disallowed the exemption claimed under section 10(23BBA) of the Act and CIT(A) sustained the decision of the It is submitted that the CIT(A) failed consider the implication of the second proviso to section 12A(2

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

disallow exemption under section 11 of the Act to assume jurisdiction to reopen the assessment. He argued that in the case of Songwoon Speciality Chemicals India (P.) Ltd. v. DCIT [2024] 169 taxmann.com 184 (Gujarat), when the claim was accepted in the original assessment proceedings and the Assessing Officer could not have reopened assessment on the same facts which were

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, 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 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

disallowed exemption on the basis that the assessee charging higher rate of interest and carrying out activities of micro finance on commercial lines and considered it as a violative of proviso to section 2(15) of the Act. It was argued that the assessee is not carrying out any activity on commercial lines, however if there are some surplus generated

M/S. INNOVATIVE MICRFINANCE FOR POVERTY ALLEVIATION & COMMUNITY TRANSFORMATION,CHENNAI vs. CIT, EXEMPTIONS,, CHENNAI

In the result, the appeal of the assessee is dismissed

disallowing /\nwithdrawing the claim of exemption u/s.11 of the Act.\n7. We have heard rival contentions and gone through facts and circumstances of\nthe case. We noted that in the case law cited by Id.counsel for the assessee, it is a\ncase of assessee holding self-help group comprising of rural poor people to avail\nthe benefit of insurance

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

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 the depreciation while working out the application of income in relation to purposes of the assessee-trust in terms of section

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)

2 hence, same may be dismissed as not pressed. The DR has no objection for the same and accordingly, the said issue is dismissed as not pressed. 3. The only surviving issue is that the CIT(A) erred in confirming action of the Assessing Officer in not allowing claim of exemption u/s.11 of the Act holding that the assessee trust

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

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

2)(a) of Income-tax Act, 1961.”\nAccordingly, the AO disallowed the claim of exemption u/s.11 of the\nAct. Aggrieved, assessee preferred appeal before the CIT(A). The\nCIT(A) also confirmed the action of the AO. Aggrieved, assessee\ncame in appeal before the Tribunal.\n4. We have heard rival contentions and gone through facts and\ncircumstances of the case

VICTORIA EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-3,, CHENNAI

The appeal of the assessee is allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:946/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2022-23 Victoria Educational Trust, Ito, 62, 6Th Street, Vs. Exemptions Ward 3, S.R.P.Colony, Chennai. Peravallur, Chennai – 600 082. [Pan:Aabtv-0115-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate प्रत्यथी की ओर से/Respondent By : Shri. Kumar Chandan, J.C.I.T.

disallowance of the claim of tax exemption u/s.11 of the Act was on account of the assessee trust filing the audit report in Form No.10B belatedly for the A.Y.2022 - 23 on application of the provisions in Section 12A(1)(b)(ii) of the Act. 8. It was submitted that the due date for filing the return of income u/s.139

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(2

SREE RAGHAVENDRA EDUCATIONAL SOCIETY,CHENNAI vs. ITO (EXEMPTIONS) WARD 4, CHENNAI

In the result, appeals filed by the assessee for both the assessment years are allowed for statistical purposes

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 834 & 835/Chny/2024 िनधा"रण वष" / Assessment Years: 2011-12 & 2015-16

2)(b) to as to confer any undue benefit directly or indirectly to the persons referred to in sub-section (3) of section 13 of the Income Tax Act to deny the assessee benefit under section 11 for alleged violation. 12. In the above circumstance the assessee submitted the order of AO is computed the income of the assessee

SREE RAGHAVENDRA EDUCATIONAL SOCIETY,CHENNAI vs. ITO (EXEMPTIONS) WARD 1, CHENNAI

In the result, appeals filed by the assessee for both the assessment years are allowed for statistical purposes

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 834 & 835/Chny/2024 िनधा"रण वष" / Assessment Years: 2011-12 & 2015-16

2)(b) to as to confer any undue benefit directly or indirectly to the persons referred to in sub-section (3) of section 13 of the Income Tax Act to deny the assessee benefit under section 11 for alleged violation. 12. In the above circumstance the assessee submitted the order of AO is computed the income of the assessee

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)

2 :: Act’) against the order dated 23.08.2022, viz the intimation order of CPC dated 29.11.2021 u/s.143(1) of the Act. 3. The main grievance of the assessee is that the CPC while processing the return of the assessee for AY 2020-21 had disallowed the exemption u/s.11 of the Act alleging failure on the part of the assessee to file

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

disallowance of depreciation. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeals before us. 11. The first issue that came up for our consideration from Ground Nos.2 to 4 of the assessee appeal for AYs 2012-13 to 2016-17 is upholding the re-opening of assessment u/s.147 of the Act. The Ld.Counsel for the assessee

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

disallowance of depreciation. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeals before us. 11. The first issue that came up for our consideration from Ground Nos.2 to 4 of the assessee appeal for AYs 2012-13 to 2016-17 is upholding the re-opening of assessment u/s.147 of the Act. The Ld.Counsel for the assessee

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

disallowance of depreciation. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeals before us. 11. The first issue that came up for our consideration from Ground Nos.2 to 4 of the assessee appeal for AYs 2012-13 to 2016-17 is upholding the re-opening of assessment u/s.147 of the Act. The Ld.Counsel for the assessee

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

disallowance of depreciation. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeals before us. 11. The first issue that came up for our consideration from Ground Nos.2 to 4 of the assessee appeal for AYs 2012-13 to 2016-17 is upholding the re-opening of assessment u/s.147 of the Act. The Ld.Counsel for the assessee