ROLAND EDUCATIONAL & CHARITABLE TRUST,BERHAMPUR vs. DCIT, BERHAMPUR CIRCLE, BERHAMPUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND EDUCATIONAL & CHARITABLE TRUST,BERHAMPUR vs. DCIT, BERHAMPUR CIRCLE, BERHAMPUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

RONALD EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND EDUCATIONAL & CHARITABLE TRUST,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND INSTITUTE OF PHARMACEUTICAL SCIENCES,GANJAM vs. CHEIF CIT, BHUBANESWAR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

ROLAND EDUCATIONAL & CHARITABLE TRUST,BERHAMPUR vs. DCIT, BERHAMPUR CIRCLE, BERHAMPUR

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

section 10(23C)(vi), it would not be justifiable, in denying approval on other grounds, especially where [he compliance depends on events that have not taken place on the date on which the application for grant of approval has been made. :- 10 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust

M/S. NABADIGANT EDUCATIONAL TRUST,BHUBANESWAR vs. ITO, WARD-2(1), BHUBANESWAR

In the result, both appeals of the assessee are dismissed

Charitable Trust VS. AQIT (Exemption) (ITAT,Delhi) (65 ITD 125), the Tribunal held that a part of trust income was being used directly or indirectly for the benefits of its founder and Managing Director - No exemption u/s. 11 or 10(22). 3.4 In view of the discussions made above and since the assessee trust violates the provisions of section

M/S. NABADIGANT EDUCATIONAL TRUST,BHUBANESWAR vs. ITO, WARD-2(1), BHUBANESWAR, BHUBANESWAR

In the result, both appeals of the assessee are dismissed

Charitable Trust VS. AQIT (Exemption) (ITAT,Delhi) (65 ITD 125), the Tribunal held that a part of trust income was being used directly or indirectly for the benefits of its founder and Managing Director - No exemption u/s. 11 or 10(22). 3.4 In view of the discussions made above and since the assessee trust violates the provisions of section

SUKANTI EDUCATIONAL AND CHARITABLE TRUST,SONEPUR vs. ITO,EXEMPTION WARD, SAMBALPUR

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

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Charitable Trust. ■ Similarly, the further reasoning offered by the Appellate Authority to affirm the order of the Assessing Authority is wholly erroneous and contrary to law. Merely because the assessee-society was the person running the institution, it did not cause any legal effect of depriving the benefit of section 10

REGIONAL COLLEGE OF ENGINEERING & MANAGEMENT,BHUBANESWAR vs. ITO, WARD-2(2), BHUBANESWAR

In the result, appeal of the assessee is allowed

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.94/Ctk/2016 (नििाारण वषा / Assessment Year :2008-2009 Regional College Of Engineering & Vs. Ito Ward-2(2), Bhubaneswar Management, Plot No.18, Sector-A, Zone-B, Mancheswar Industrial Estate, Bhubaneswar-751010 Pan No. : Aaaar 1386 H (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri Sunil Mishra, Advocate राजस्व की ओर से /Revenue By : Shri Subhendu Datta, Dr सुनवाई की तारीख / Date Of Hearing : 20/08/2020 घोषणा की तारीख/Date Of Pronouncement : 21/08/2020 आदेश / O R D E R Per L.P.Sahu, Am: This Is An Appeal Filed By The Assessee Against The Order Of The Cit(A)-3, Bhubaneswar, Dated 28.12.2015 For The Assessment Year 2008-2009, On The Following Grounds Of Appeal :- 1. That, The Learned Cit (A) Has Committed Serious Error In Not Allowing The Appeal Of The Appellant Against The Order Of The Learned Ao Passed U/S 154 Of The Income Tax Act Dated 15.10.2014 . 2. That, The Learned Cit (A) Has Committed Serious Error In Not Accepting That The Denial Of "Emption To A Charitable Trust Granted Registration U/S 12Aa Of The Income Tax Act Is A Mistake Apparent From Record As Envisaged U/S 154 Of The Income Tax Act, 1961. 3. That, The Learned Cit (A) Has Committed Serious Error In Holding That The Mistake Of Disallowance For Violation Of Provision Of Section 40(A)(Ia) Of The Income Tax Act Is Not A Mistake Apparent From Record In The Case Of A Charitable Trust Registered U/S 12Aa Of The Income Tax Act.

trust or institution, shall not be treated as application of income for charitable or religious purposes.] [Explanation 3.—For the purposes of determining the amount of application under clause (a) or clause (b), the provisions of sub-clause (ia) of clause (a) of section 40 and sub-sections (3) and (3A) of section 40A, shall, mutatis mutandis, apply as they

STATE POLLUTION CONTROL BOARD ODISHA,BHUBANESWAR vs. ITO, WARAD 5(2), BHUBANESWAR, BHUBANESWAR

In the result, appeal of the assessee stands allowed and stay petition stands dismissed

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwals.P.No.11/Ctk/2024 Assessment Year :2017-18 State Pollution Control Board State Pollution Control Board, Vs. Ito, Ward 5(2), Plot No.A-118, Paribesh Bhawan, 118, Paribesh Bhawan, Bhubaneswar Nilakantha Nagar, Agar, Nayapali, Nayapali, Unit-Vii, Bhubaneswar Neswar Pan/Gir No.Aaals 2490 J Aaals 2490 J (Appellant) (Appellant .. ( Respondent Respondent) Assessee By : Shri S.K.Agrawalla, Ca Walla, Ca Revenue By : Shri Sanjay Kumar, Cit Sanjay Kumar, Cit Dr Date Of Hearing : 24/10/20 2024 Date Of Pronouncement : 24/10/20 024 O R D E R Per Bench

trust or venture capital company or venture capital fund is assessable, without giving effect to the provisions of section 10, exceeds the maximum amount which is not chargeable to income-tax, furnish a return of such income of the previous year in the prescribed form and verified in the prescribed manner and setting forth such other particulars

DINABANDHU FOUNDATION FOR EDUCATIONAL RESEARCH & SOCIO ECONOMIC DEVELOPMENT,BHUBANESWAR vs. ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER/INCOME TAX OFFICER, NFAC, DELHI

In the result, appeal of the assessee is allowed and stay application of the assessee stands dismissed

Bench: Shri George Mathan & Shri Madhusudan Sawdiaआयकर अपील सं/Ita No.450/Ctk/2025 रोक आवेदन सं/Sa No.6/Ctk/2025 (Arising Out Of Ita No.450/Ctk/2025) (नििाारण वर्ा / Assessment Year : 2018-2019) Vs Additional/Joint/Deputy/Assistant Dinabandhu Foundation For Educational Research & Socio Commissioner/Income Tax Economic Development, Officer/Nfac, Delhi A/127, Saheed Nagar, Bhubaneswar-751007 Pan No. :Aaatd 7338 L (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri Dilip Kumar Mohanty, Advocate & Shri Pradyumna Kumar Sahu, Advocate राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2026 घोषणा की तारीख/Date Of Pronouncement : 20/02/2026 आदेश / O R D E R Per Bench : The Assessee Has Filed Stay Application Along With Appeal In Ita No.450/Ctk/2025 For The Assessment Year 2018-2019 Against The Order Dated 21.07.2025 Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Thereby Disallowing The Exemption Claimed By The Assessee Trust U/S.11(2) Of The Act On The Ground That The Purpose Mentioned In Form No.10 Was Too Vague & Lacked The Required Specificity. 2. It Was Submitted By The Ld.Ar That The Assessee Had During The Impugned Assessment Year Filed Its Form No.10 Which Reads As Follows:-

Charitable or religious trust - Exemption of income from property held under (Accumulation of fund) - Assessment year 2008-09 - Whether lack of declaration in Form No. 10 regarding specific purpose for which funds were being accumulated by assessee-trust, would not be fatal to exemption claimed under section