DR. VIRENDRA SWAROOP EDUCATIONAL FOUNDATION,KANPUR vs. ACIT, CENTRAL CIRCLE, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2023-24] Dr. Virendra Swaroop Vs Acit Educational Foundation Central Circle 15/96, Civil Lines, Kanpur Dehradun Uttar Pradesh-208001 Pan-Aaajd0224D Appellant Respondent Assessee By Shri Salil Kapoor, Adv. Shri Rajiv Sahni, Ca Shri Sumit Lal Chandanim, Adv. Shri Shivam Yadav, Adv. & Ms. Ananya Kapoor, Adv. Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 16.09.2025 By Ld. Pr. Commissioner Of Income Tax (Central), Kanpur [“Pcit”] Passed U/S 12(Ab)(4)(Ii) Of The Income Tax Act, 1961[“The Act”] Cancelling The Registration Granted U/S 12A Of The Act From Assessment Year 2023-24 & Onwards.

gains of the real estate business of sale, purchase and leasing activities can be termed as incidental to the attainment of trust's objectives and are in the nature of commercial activities carried out for purposes other than for the objects of the trust. Therefore, vide impugned order, ld. PCIT has cancelled the registration granted u/s 12A/12AA or 12AB

DY. COMMISSISSIONER OF INCOME TAX, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LIMITED, MUMBAI

In the result, Appeals of the Revenue's are dismissed\nOrder pronounced in the open court on\nSd/-\n(MANISH AGARWAL)\nACCOUNΤΑΝΤ ΜΕMBER\nDate: 28

capital tools M.E. Ltd.\nunder the head \"Salaries\".\nThe assessee does not get the benefit of exclusionary clause 2 of sec.\n9(1)(vii) since this activity executing annual maintenance contract and\nconsultancy is not a mining activity and is purely technical service.\nSimilarly, these nature of activities are not covered under provisions of\nsec. 44BB and royalty in nature