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

12A of the Act entitles exemption\nunder section 11 of the Act is misconceived. She argued that the\nregistration confirms charitable character, but, not automatic exemption\nand exemption under section 11 of the Act requires income from\ncharitable activities in the relevant year as held by the Hon'ble High Court\nof Karnataka in the case of Fr. Mullers Charitable

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:

reassessment order u/s.143(3) r.w.s.147 of the Act was passed on 18.07.2011 and registration u/s.12A of the Act was granted to assessee on 21.06.2013 w.e.f. A.Y.2010-2011, therefore, in the year under consideration i.e. A.Y.2009-10, the assesse was not having registration u/s.12A of the Act. He also contended that the first proviso to section 12A(2) of the Act cannot

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

u/s 143(3) of the Act, the assessments cannot be reopened after four years from the end of the relevant assessment year, unless there is a failure on the part of the assessee to disclose fully and truly all material facts necessary for that assessment year. In other words, if the AO wants to re-open the assessment after four

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

u/s 143(3) of the Act, the assessments cannot be reopened after four years from the end of the relevant assessment year, unless there is a failure on the part of the assessee to disclose fully and truly all material facts necessary for that assessment year. In other words, if the AO wants to re-open the assessment after four

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

u/s 143(3) of the Act, the assessments cannot be reopened after four years from the end of the relevant assessment year, unless there is a failure on the part of the assessee to disclose fully and truly all material facts necessary for that assessment year. In other words, if the AO wants to re-open the assessment after four

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

u/s 143(3) of the Act, the assessments cannot be reopened after four years from the end of the relevant assessment year, unless there is a failure on the part of the assessee to disclose fully and truly all material facts necessary for that assessment year. In other words, if the AO wants to re-open the assessment after four

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

u/s 143(3) of the Act, the assessments cannot be reopened after four years from the end of the relevant assessment year, unless there is a failure on the part of the assessee to disclose fully and truly all material facts necessary for that assessment year. In other words, if the AO wants to re-open the assessment after four

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

u/s 143(3) of the Act, the assessments cannot be reopened after four years from the end of the relevant assessment year, unless there is a failure on the part of the assessee to disclose fully and truly all material facts necessary for that assessment year. In other words, if the AO wants to re-open the assessment after four

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

u/s 143(3) of the Act, the assessments cannot be reopened after four years from the end of the relevant assessment year, unless there is a failure on the part of the assessee to disclose fully and truly all material facts necessary for that assessment year. In other words, if the AO wants to re-open the assessment after four

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)

147 of the Income Tax Act, 1961(hereinafter “the Act”) vide order dated 24.03.2014. 2. The first jurisdictional issue raised by the assessee is with regard to reassessment and assumption of jurisdiction u/s.147 of the Act. At the outset, learned counsel for the assessee stated that he is not prosecuting this issue and 2 hence, same may be dismissed

THIRUVARUR LIONS EYE HOSPITAL TRUST,THIRUVARUR vs. INCOME TAX OFFICER, THIRUVARUR

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

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.: 2531 & 2535/Chny/2025 िनधा"रण वष"/Assessment Years: 2016-17 & 2018-19 M/S. Thiruvarur Lions Eye The Income Tax Officer, Hospital Trust, Vs. Thiruvarur 157, Vandampalai, Kangalanchery Post, Thiruvarur – 610 101. Pan: Aaatt 0632P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri D. Ambarish, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.11.2025

147 was completed by accepting the return of income filed by the appellant declaring NIL income and NIL tax liability. and therefore, there was no loss to the Revenue 3. The penalty is unwarranted as the very foundation of section 272A(2)(e) is penal in nature and requires deliberate default, whereas in the appellant's case, the omission

THIRUVARUR LIONS EYE HOSPITAL TRUST,THIRUVARUR vs. INCOME TAX OFFICER, THIRUVARUR

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

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.: 2531 & 2535/Chny/2025 िनधा"रण वष"/Assessment Years: 2016-17 & 2018-19 M/S. Thiruvarur Lions Eye The Income Tax Officer, Hospital Trust, Vs. Thiruvarur 157, Vandampalai, Kangalanchery Post, Thiruvarur – 610 101. Pan: Aaatt 0632P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri D. Ambarish, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.11.2025

147 was completed by accepting the return of income filed by the appellant declaring NIL income and NIL tax liability. and therefore, there was no loss to the Revenue 3. The penalty is unwarranted as the very foundation of section 272A(2)(e) is penal in nature and requires deliberate default, whereas in the appellant's case, the omission

PKD TRUST,CHENNAI vs. ITO, POLLACHI

Appeal stands dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita No.2053/Mds/2014 आयकर अपील सं./Ita Nos.1820 & 1819/Mds/2016 "नधा"रण वष" / Assessment Years : 2010-11 & 2012-13 M/S Pkd Trust, The Income Tax Officer, Pkd Matriculation School, V. Ward I(2) / Ward 1(1), Coimbatore Road, Pollachi. Pollachi – 642 001. Pan : Aaaap 1297 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 10(23C) of the Act without assigning proper reasons and justification. (3) The CIT(Appeals) erred in sustaining the assessment of `1,01,81,782/- in the computation of taxable total income without assigning proper reasons and justification. (4) The CIT(Appeals) failed to appreciate that there was no proper opportunity given before the passing of the impugned order

P.K.D.TRUST,CHENNAI vs. ITO, POLLACHI

Appeal stands dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita No.2053/Mds/2014 आयकर अपील सं./Ita Nos.1820 & 1819/Mds/2016 "नधा"रण वष" / Assessment Years : 2010-11 & 2012-13 M/S Pkd Trust, The Income Tax Officer, Pkd Matriculation School, V. Ward I(2) / Ward 1(1), Coimbatore Road, Pollachi. Pollachi – 642 001. Pan : Aaaap 1297 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 10(23C) of the Act without assigning proper reasons and justification. (3) The CIT(Appeals) erred in sustaining the assessment of `1,01,81,782/- in the computation of taxable total income without assigning proper reasons and justification. (4) The CIT(Appeals) failed to appreciate that there was no proper opportunity given before the passing of the impugned order

P.K.D.TRUST,CHENNAI vs. ITO, POLLACHI

Appeal stands dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita No.2053/Mds/2014 आयकर अपील सं./Ita Nos.1820 & 1819/Mds/2016 "नधा"रण वष" / Assessment Years : 2010-11 & 2012-13 M/S Pkd Trust, The Income Tax Officer, Pkd Matriculation School, V. Ward I(2) / Ward 1(1), Coimbatore Road, Pollachi. Pollachi – 642 001. Pan : Aaaap 1297 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 10(23C) of the Act without assigning proper reasons and justification. (3) The CIT(Appeals) erred in sustaining the assessment of `1,01,81,782/- in the computation of taxable total income without assigning proper reasons and justification. (4) The CIT(Appeals) failed to appreciate that there was no proper opportunity given before the passing of the impugned order

K.SURESH,CHENNAI vs. DCIT, CHENNAI

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

u/s 147 of the Act. 5.2 In the present case, the assessee has not shown bank account with Axis Bank, Adyar Branch, Chennai. As per Explanation 2 of Section147, it is very clear that due to non- disclosure of this by the assessee, the income chargeable to tax had escaped assessment. The assessee has not produced anything before the Commissioner

K.SURESH,CHENNAI vs. DCIT, CHENNAI

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

u/s 147 of the Act. 5.2 In the present case, the assessee has not shown bank account with Axis Bank, Adyar Branch, Chennai. As per Explanation 2 of Section147, it is very clear that due to non- disclosure of this by the assessee, the income chargeable to tax had escaped assessment. The assessee has not produced anything before the Commissioner

K.SURESH,CHENNAI vs. DCIT, CHENNAI

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

u/s 147 of the Act. 5.2 In the present case, the assessee has not shown bank account with Axis Bank, Adyar Branch, Chennai. As per Explanation 2 of Section147, it is very clear that due to non- disclosure of this by the assessee, the income chargeable to tax had escaped assessment. The assessee has not produced anything before the Commissioner