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 to sub-section (2

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

SMT. LINGAMMAL RAMARAJU SHASTRA PRATHISHTA TRUST,RAJAPALAYAM vs. ACIT (EXEMPTIONS), COIMBATORE

In the result, the appeal stands allowed

Section 2(15) of the\nAct. With these observations, the Ld. CIT(E) directed the AO to deny the\nexemption u/s 11 of the Act.\n7. Being aggrieved by the impugned order of the Ld. CIT(E), the\nassessee has preferred the present appeal before us.\n8. Assailing the action

KALYANASUNDARAM SURESH,CHENNAI vs. ACIT NON CORPORATE CIRCLE 2, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.297/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 Shri Kalyanasundaram Suresh, Vs. The Assistant Commissioner Of Old No. 12-A, New No. 24, Income Tax, Swarnamangalam East Road, West Non Corporate Circle 2, Cit Nagar, Nandanam, Chennai. Chennai 600 035. [Pan: Aobps4696F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ravi Kannan, Advocate & Shri Varun Ranganathan, Advocate ""थ" की ओर से/Respondent By : Shri R.V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 23.07.2024 घोषणा की तारीख /Date Of Pronouncement : 28.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.12.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals)-2, Chennai For The Assessment Year 2013-14. 2. The Ld. Ar Shri K. Ravi Kannan, Advocate Drew Our Attention To The Additional Grounds Of Appeal Filed On 10.12.2023 & Submits That The Said 3 Grounds Of Appeal May Be Taken Up First The Ld. Dr Shri R.V.

12A) of the Act also supports that bank pass book cannot be treated as books of accounts. 11.16 He has also placed reliance on the order of the Tribunal, Mumbai Bench in the case of Smt. Mansai Mahendra Pitkar vs. ITO (73 taxmann.com 68) (Mumbai Trib). Therefore, it is prayed that addition u/s.68 based on entries in bank pass book

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

2. The NFAC, Delhi erred in sustaining the disallowance of the claim of expenditure to the tune of Rs. 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

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)

12A." 11 In the instant case, AO and CIT(A) have tried to bring in rigors of section 68 of the Act . In light of the Hon’ble Delhi High Court, the conclusion of AO and CIT(A) is not legally tenable. We also rely on the ITAT orders cited in para 6 of this order, wherein

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

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

CENTRE FOR URBANISATION BUILDINGS AND ENVIRONMENT (CUBE), ,CHENNAI vs. ITO, EXEMPTIONS WARD 4,, CHENNAI

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.3280/Chny/2024 िनधा9रण वष9 /Assessment Year: 2024-25

68 73 Gujarat High Court - Hiralal Bhagwati – [2000] 246 ITR 188 (GUJ.) 12 74 75 Supreme Court - Surat City Gymkhana [2008] 170 Taxman 612 (SC) Gujarat High Court - N.N. Desai Charitable Trust - [2002] 123 Taxman 866 13 76 82 (Gujarat) ITAT Lucknow - Shiv Raj Sharma Shiksha Samiti Bilaspur - ITA 14 83 87 No.78/LKW/2018 – order dated 16-5-2019 Supreme Court

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

2) of the Act was issued on 30.06.2021. Thereafter, multiple notices were issued to which the assessee had filed its responses. The Assessing Officer, thereafter, passed the assessment order u/s.143(3) r.w.s.144B of the Act on 05.09.2022 wherein he stated that assessee has no valid registration u/s.12A of the Act and therefore is ineligible to claim exemption us/.11

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