ITO, NCW - I (4),, CHENNAI vs. SHRI KANAKILLIYANALLUR NARAYANAN NEHRU,, CHENNAI

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

68 cannot be pressed into service. Thus, it is crystal clear that mere bank statement which is issued by bank to its client etc., can’t be elevated to status of books maintained by assessee within the meaning .of section 2(12A

DICT, CORPORATE CIRCLE - 2 (1),, CHENNAI vs. M/S. GSNR RICE INDUSTRIES PVT. LTD.,, CHENNAI

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

68 cannot be pressed into service. Thus, it is crystal clear that mere bank statement which is issued by bank to its client etc., can’t be elevated to status of books maintained by assessee within the meaning .of section 2(12A

DCIT, CORPORATE CIRCLE - 2 (1),, CHENNAI vs. SHRI KANAKKILIANALLUR NARAYANA REDDIYAR MANIVANNAN,, TIRUPUR

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

68 cannot be pressed into service. Thus, it is crystal clear that mere bank statement which is issued by bank to its client etc., can’t be elevated to status of books maintained by assessee within the meaning .of section 2(12A

DICT, CORPORATE CIRCLE - 2 (1),, CHENNAI vs. M/S. GSNR RICE INDUSTRIES PVT. LTD.,, CHENNAI

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

68 cannot be pressed into service. Thus, it is crystal clear that mere bank statement which is issued by bank to its client etc., can’t be elevated to status of books maintained by assessee within the meaning .of section 2(12A

DICT, CORPORATE CIRCLE - 2 (1),, CHENNAI vs. M/S. GSNR RICE INDUSTRIES PVT. LTD.,, CHENNAI

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

68 cannot be pressed into service. Thus, it is crystal clear that mere bank statement which is issued by bank to its client etc., can’t be elevated to status of books maintained by assessee within the meaning .of section 2(12A

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:

68 taxmann.com 152 (Enclosed in Annexure-2) 7.2 When section 12A of the Act was amended by introducing new provisos

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)

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 precedent

DEPUTY COMMISSIONER OF INCOME-TAX, MADURAI vs. STANDARD FIREWORKS PRIVATE LIMITED, SIVAKASI, TAMILNADU

In the result, appeals filed by the Revenue and Cross-Objections\nfiled by the assessee are dismissed

Section 12A registered\norganization which was also added by the AO. The Ld.CIT(A) noted that\nall the records including the audited financials and data from the\ncomputerized register maintained in its Oracle software were retrieved by\nthe Investigation Team and was before the AO while he was scrutinizing\nthe assessment which resulted in additions made

NILAA CHARITABLE TRUST,VILLUPURAM vs. ITO, EXEMPTIONS WARD-1, CHENNAI

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

Bench: SHRI GEORGE GEORGE K (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)

68 of the Act has no application in the case of trust. The relevant finding of the Hon’ble High Court read as follows:- "The assessee was a charitable trust providing medical advice for needy people in various parts and remote villages of Uttar Pradesh. It was registered under section 12A

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

68,612 /- incurred in relation to the donations and consequently erred in sustaining the addition of such sum in the computation of taxable total income without assigning proper reasons and justification. 3. The NFAC, Delhi erred in sustaining the disallowance of the claim of certain expenses / purchase equipment at Rs. 6,35,450/- and consequently erred in sustaining the addition

PREM EDUCATIONAL TRUST,VELLORE vs. ITO EXEMPTION WARD-1, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Jagadish

68-B, MC Road, Ward-1, Vellore-635 802. Chennai. [PAN: AABTP 9849 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Mr.Abhishek Murali, CA (by virtual) ""यथ" क" ओर से /Respondent by : Mr.Bipin C.N., CIT : सुनवाईक"तारीख/Date of Hearing 04.07.2025 : घोषणाक"तारीख /Date of Pronouncement 15.07.2025 आदेश / O R D E R PER ABY T. VARKEY

SRI VENKATESWARA ORPHANAGE KADUVELI,THANJAVUR vs. ITO, EXEMPTION WARD,, TRICHY

In the result, the appeal of the assessee is partly allowed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

section 12A(1)(ac) inserted by Finance Act, 2020 :-4-: ITA. No:1679/Chny/2025 w.e.f.01.06.2020 has been omitted by Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (hereinafter referred to as TOLA), with retrospective effect from 01.06.2020. Therefore, the order passed by the ld.CIT(E) rejecting registration u/s.12A dated

SREE VENKATESWARA EDUCATIONAL TRUST,KRISHNAGIRI vs. ITO, EXEMPTIONS WARD,, SALEM

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

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. Nos. 1338 & 1339/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 Sree Venkateswara Educational Trust, The Income Tax Officer, 655/20 & 600, Jagilkathirampatti Vs. Exemptions Ward, Village & Post, Pochampalli Taluk, Salem. Krishnagiri District 635 206. [Pan:Aaits5220J ] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Jcit सुनवाई की तारीख/ Date Of Hearing : 10.12.2019 घोषणा की तारीख /Date Of Pronouncement : 30.12.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), Salem, Both Dated 25.03.2019 For The Assessment Year 2013-14 Passed Against The Order Under Section 143(1) Of The Income Tax Act, 1961 [“Act” In Short] As Well As Under Section 154 Of The Act. Against The Order Under Section 154 Of The Act, The Assessee Has Raised Following Grounds: “1. The Commissioner Of Income-Tax (Appeals) Is Not Justified In Holding That Non-Allowance Of Expenditure Incurred To Earn Gross Receipts From A College & School Involves A Complex & Debatable Legal Issue.

68 ITD 95 Mum, 135 ITR 485 Mad, 56 ITD 37 Del Trib, 125 ITR 531 MP, 162 ITR 612 Guj). 5. Application made for charitable purposes out of income earned alone is allowable, only if a Trust is registered under section 12AA and not the expenses incurred for purpose of earning income. 6. Observation of the Commissioner (Appeals

SREE VENKATESWARA EDUCATIONAL TRUST,KRISHNAGIRI vs. ITO, EXEMPTIONS WARD,, SALEM

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

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. Nos. 1338 & 1339/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 Sree Venkateswara Educational Trust, The Income Tax Officer, 655/20 & 600, Jagilkathirampatti Vs. Exemptions Ward, Village & Post, Pochampalli Taluk, Salem. Krishnagiri District 635 206. [Pan:Aaits5220J ] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Jcit सुनवाई की तारीख/ Date Of Hearing : 10.12.2019 घोषणा की तारीख /Date Of Pronouncement : 30.12.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), Salem, Both Dated 25.03.2019 For The Assessment Year 2013-14 Passed Against The Order Under Section 143(1) Of The Income Tax Act, 1961 [“Act” In Short] As Well As Under Section 154 Of The Act. Against The Order Under Section 154 Of The Act, The Assessee Has Raised Following Grounds: “1. The Commissioner Of Income-Tax (Appeals) Is Not Justified In Holding That Non-Allowance Of Expenditure Incurred To Earn Gross Receipts From A College & School Involves A Complex & Debatable Legal Issue.

68 ITD 95 Mum, 135 ITR 485 Mad, 56 ITD 37 Del Trib, 125 ITR 531 MP, 162 ITR 612 Guj). 5. Application made for charitable purposes out of income earned alone is allowable, only if a Trust is registered under section 12AA and not the expenses incurred for purpose of earning income. 6. Observation of the Commissioner (Appeals

M/S. SUBHIKSHA HIND VIDHYALAYA,MAYILADUTHURAI vs. CIT EXEMPTIONS, , CHENNAI

In the result, both the appeals filed by the assessee are allowed\nfor statistical purposes

68,975/- to various teachers shown under\nthe head honorarium out of total receipts of Rs.8,10,153/- . The Ld AR\nhas submitted that the Ld. CIT(E) has not gone through the accounts\nand activities of the trust and requested one more opportunity be\ngranted to prove its case.\n4. On the other hand, the Ld. Departmental Representative

M/S. SUBHIKSHA HINDI VIDHYALAYA,MAYILADUTHURAI vs. CIT, EXMETIONS,, CHENNAI

In the result, both the appeals filed by the assessee are allowed\nfor statistical purposes

68,975/- to various teachers shown under\nthe head honorarium out of total receipts of Rs.8,10,153/- . The Ld AR\nhas submitted that the Ld. CIT(E) has not gone through the accounts\nand activities of the trust and requested one more opportunity be\ngranted to prove its case.\n4. On the other hand, the Ld. Departmental Representative

DEPUTY COMMISSIONER OF INCOME TAX, MADURAI vs. M/S. STANDARD FIREWORKS PRIVATE LIMITED, SIVAKASI, TAMILNADU

In the result, appeals filed by the Revenue and Cross-Objections

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 12A registered organization which was also added by the AO. The Ld.CIT(A) noted that all the records including the audited financials and data from the computerized register maintained in its Oracle software were retrieved by the Investigation Team and was before the AO while he was scrutinizing the assessment which resulted in additions made

ASSISTANT COMMISSIONER OF INCOME TAX(EXEMPTIONS), COIMBATORE vs. MAZDOOR WELFARE TRUST, TIRUVARUR

In the result, the appeal of the revenue is dismissed

Bench: Shri Manu Kumar Giri, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 515/Chny/2024 िनधा"रणवष" / Assessment Year: 2007-08 Mazdoor Welfare Trust, Assistant Commissioner Of V. Kovilvenni S.O. , Income Tax (Exemptions), Krishnapuram, 2Nd Floor, Mayflowe Mideity Thiruvarur – 614 403. Building, 1510 Trichy Road, [Pan:Aaatm-0632-Q] Coimbatore – 641 018. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Nilay Baran Som, Cit ""यथ"क"ओरसे/Respondent By : Shri. G. Baskar, Advocate सुनवाई क" तारीख/Date Of Hearing : 26.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 27.11.2024 आदेश /O R D E R Per S. R. Raghunatha:

Section 12A(b)? 2.3 The ld.CIT(A) erred in not considering the fact that accounts submitted by the assessee for the AY 2007-08 were not full and complete without inclusion of the accounts of 'Balamurugan Hostel/ Mess '? 2.4 Whether the ld.CIT(A) was right in overlooking the auditor’s report that “the accounts of Balamurugan Hostel/Mess have