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

In the result, both appeals of the assessee are dismissed

Charitable Trust v. DIT(Exemp.) (2008 297 ITR 66(Del.) wherein the Hon'ble Court held: "6. The basic requirement for the availability for exemption under. sections 11 and 12 of the Act is that if any money is lent to an interested party as defined in section 13 (3

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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

Appeals are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

3)/147 dated 26/03/2013, as under: “6. Roland Educational & Charitable Trust is a Trust, registered under Indian Trust Act vide registration No :- 35 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur 409 of l997 dated 19.11.1997. On perusal of the Trust Deed, it is seen that the objects of the Trust contain both educational as well as noneducational

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.

charitable trust, which is duly registered under Section 12A and accordingly its income and expenditure is computed in terms of section 11. The issue before us is whether the disallowance under Section 40(a)(ia) can be made for the non- deduction of TDS under Section 194 in the case of such kind of assessees. Under the Income

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:-

11(2) of the Act?" 6 SA No.06/CTK/2025 3. Both questions are arising out of same issue. Such issue arises in following background: 4. Respondent-assessee is a Public Charitable Trust. For the assessment year 2008-09, the assessee had filed the return of income claiming deduction of a sum of Rs. 3.60 crores under section

ORISSA OLYMPIC ASSOCIATION,CUTTACK vs. CIT(EXEMPTIONS), HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahuassessment Year : 2009-2010

11(1)(a) of the Act the lease rent incomes from the property held under the trust are wholly for charitable or religious purposes which is applied for the charitable purposes of trust income then, same is not taxable and exempt in the hands of trust or institution. From the vigilant reading of the impugned order, we clearly see that

DY.CIT(EXP), BHUBANESWAR vs. M/S. ORISSA COMPUTER ACADEMY, BHUBANESWAR

In the result, appeals filed by the revenue and cross objections of the

Bench: S/Shri P.M. Jagtap & C.M. Garg

trust has been misused for payment of remuneration. 7. The Assessing Officer further observed that according to the provisions of section 11(4), the running of educational institution is a business and not incidental to the fulfilment of the objectives of the assessee society. Hence, income from such institutions are taxable even when section 11 is valid. 8. The Assessing