M/S GIAN SAGAR EDUCATIONAL & CHARITABLE TRUST,,CHANDIGARH vs. DCIT, NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri C.M. Garg & Shri M. Balaganeshm/S. Gian Sagar Educational Vs. Dcit & Charitable Trust, Central Circle-29, Sco 10-110, Sector 43B, New Delhi Chandigarh (Appellant) (Respondent) Pan:Aaatg5827B

Charitable Trust [totaling to Rs.22,53,53,785/-] on account of non-genuineness and creditworthiness of the of the donors. The reason for such disallowance

GIAN SUGAR EDUCATIONAL AND CHARITABLE TRUST (REGD.),CHANDIGARH vs. DCIT, NEW DELHI

In the result, ITA.No.4692/Del

Bench: Shri Anil Chaturvedi & Shri Anubhav Sharma

Charitable Trust (Regd.), Chandigarh. under section 115BBC read with Section 68 of the I.T. Act, 1961 at Rs.12,50,83,785/- and Rs.10,02,70,000/- [totalling to Rs.22,53,53,785/-] on account of non-genuineness and creditworthiness of the of the donors. The reason for such disallowance

DCIT, NEW DELHI vs. M/S. GIAN SAGAR EDUCATIONAL & CHARITABLE TRUST (REGD.), CHANDIGARH

In the result, ITA.No.4692/Del

Bench: Shri Anil Chaturvedi & Shri Anubhav Sharma

Charitable Trust (Regd.), Chandigarh. under section 115BBC read with Section 68 of the I.T. Act, 1961 at Rs.12,50,83,785/- and Rs.10,02,70,000/- [totalling to Rs.22,53,53,785/-] on account of non-genuineness and creditworthiness of the of the donors. The reason for such disallowance

DCIT (E), NEW DELHI vs. M/S SPIRITUAL REGENERATION MOVEMENT FOUNDATION OF INDIA,, NEW DELHI

Bench: Sh. N. K. Billaiya & Sh. Kul Bharatassessment Year: 2011-12

disallowance is upheld.” 21. Before us the Counsel reiterated what has been stated before the lower authorities and the DR strongly supported the findings of the AO/ CIT(A). We have carefully perused the orders of the authorities below. The quarrel is where a trust incurs a debt for the purposes of the trust, whether the repayment of the debt

ITO (E), NEW DELHI vs. BHAI HOSPITAL TRUST, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. C. M. Garg & Sh. N.K. Billaiyaassessment Year: 2007-08 Ito (E) Bhai Hospital Trust Trust Ward-Iii Vs 55, Hanuman Road, Laxmi Nagar Distt. Centre Connaught Place, New Delhi New Delhi-1100001 Pan No.Aaatb0492M (Appellant) (Respondent)

disallowed as application, in absence of any plausible purposes or prudence, being unexplained in nature. 8. Having conclusively satisfied that the donee trust has not carried out any charitable

RICHMOND EDUCATIONAL SOCIETY,NOIDA vs. DCIT/ACIT CENTRAL CIRCLE, GHAZIABAD, GHAZIABAD

In the result, the appeal of the Assessee is allowed

trust registered with the stated object of\nimparting education is, in reality, carrying on activities primarily in the\nnature of relief to the poor or other charitable purposes unrelated to\neducation, the registration may be liable to be withdrawn. In the instant\ncase before us, the activities carried out by the Assessee Society of\nimparting education is not even doubted

PRABHU SARAN GARG CHARITABLE TRUST,NEW DELHI vs. JCIT, GHAZIABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 3558/Del/2015 : Asstt. Year 2010-11 Prabhu Saran Garg Charitable Vs. Jcit, Trust, C/O M/S O.P. Sapra & Range-2, Associates, C-763, New Friends Ghaziabad Colony, New Delhi-110025 (Appellant) (Respondent) Pan No. Aaatp9634M Assessee By : Sh. Akhilesh Kumar, Adv. Revenue By : Sh. Girish Kumar Kohali, Sr. Dr Date Of Hearing: 26.07.2022 Date Of Pronouncement: 11.08.2022

disallowing exemption claimed. 2. That, learned commissioner of income tax (Appeals) manifestly erred in rejecting the contention that alleged advances made to three 2 Prabhu Saran Garg Charitable Trust

RAM SARAN DAS KISHORI LAL CHARITABLE TRUST,DELHI vs. CIT(EXEMPTION), DELHI

The appeal of the assessee is allowed

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma[Assessment Year: -------] Ram Saran Das Kishori Lal Commissioner Of Income Tax Charitable Trust, (Exemption), Room No.24.05, E-2 Block, 24Th Floor, Civic Centre, A-27, Friends Colony East, Vs New Delhi-110001 New Delhi-110002 Pan-Aaatr0783P Appellant Respondent Appellant By Shri Ajay Vohra, Sr. Adv. & Shri Aditya Vohra, Adv. Shri Arpit Goyal, Adv. Respondent By Shri Amit Jain, Cit-Dr Date Of Hearing 09.09.2025 Date Of Pronouncement 12.11.2025

disallowances unless the Trust and its Trustees are directly held responsible for any criminal action or an act of breach of public trust. Reliance can be placed for this proposition on decision of Mumbai Tribunal in Padmashree Dr DY Patil-University vs DCIT: (2024] 159 taxmann.com 353 (Mumbai Trib.) and Guru Gobind Singh Educational Society

CONFRERE EDUCATIONAL SOCIETY,NOIDA vs. ITO (EXEMPTION), NOIDA

In the result, the appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharma

disallowed if the source of income held under the trust is under legal obligation and here the assessee was under obligation to apply the income for charitable

DCIT, CENTRAL CIRCLE, NOIDA vs. PGP CHARITABLE TRUST, DELHI

In the result, both the appeals of the revenue are dismissed

Bench: Shri Amit Shukla & Shri M. Balaganesh

Charitable trust were furnished, as such wing gave a finding that trust was receiving its own unaccounted funds in the form of donations. The cases of this group are interconnected and required deep investigation to arrive at a logical conclusion. As such, for taking a logical conclusion in this group of cases, every single seized/impounded document and entry appearing

DCIT, CENTRAL CIRCLE, NOIDA vs. PGP CHARITABLE TRUST, DELHI

In the result, both the appeals of the revenue are dismissed

Bench: Shri Amit Shukla & Shri M. Balaganesh

Charitable trust were furnished, as such wing gave a finding that trust was receiving its own unaccounted funds in the form of donations. The cases of this group are interconnected and required deep investigation to arrive at a logical conclusion. As such, for taking a logical conclusion in this group of cases, every single seized/impounded document and entry appearing

ACIT (E), CIRCLE- 2(1), NEW DELHI vs. SANSKRITI EDUCATIONAL SOCIETY, NEW DELHI

Appeal is dismissed

Bench: Shri Tarvinder Singh Kapoor & Shri Chandra Mohan Garg

Charitable Trust (supra), the Division Bench could not have taken a different view on the legal ratio as interpreted in Vishwa Jagriti Mission (supra). Further, the decisions in the case of Vishwa Jagriti Mission and Indian Trade Promotion Organisation (supra) being prior in point of time would act as binding precedents and could not have been overruled or dissented from

GOPURI CHARITABLE TRUST,NEW DELHI vs. DCIT CPC, BANGALORE

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

Bench: Shri Shamim Yahya & Shri Yogesh Kumar U.S.

charitable trust registered u/s 12A of the Income Tax Act is entitled to claim deduction u/s 80G/80GGA of the Act. The relevant portion of the same is as under:- “7. We find that in the preceding AY i.e. AY 2013-14 and in the succeeding AY i.e. AY 2015-16 the assessee's claim of deduction under section 80G/80GGA

CARE TODAY FUND,NEW DELHI vs. ITO WARD EXEMPTION 1(3), CIVIC CENTRE NEW DELHI

In the result, the appeal of assessee is allowed

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Care Today Fund, Vs. Income Tax Officer, F-26, First Floor, Exemption 1(3), Connaught Place, New Delhi New Delhi-1100 01 Pan :Aaatc3762B (Appellant) (Respondent)

disallowing expenditure. Undisputedly, the assessee is a charitable trust. The assessee had filed copies of agreement with organization providing repairs

DSOB CLASS OF 64 CHARITABLE TRUST,DELHI vs. DCIT, CPC, DELHI

Appeal of the assessee is allowed in terms stated above

Bench: Shri Kul Bharat

disallowing the statutory deduction of Rs 57,219/- claimed by the assessee under Section 11(1)(a) of the Act, being the amount accumulated or set apart for application to charitable purposes to the extent it does not exceed 15% of income held in trust

ICLEI LOCAL GOVERNMENT FOR SUSTAINABILITY SOUTH ASIA,NEW DELHI vs. ITO(EXEMPTION), WARD-1(2), NEW DELHI

In the result, the appeal of the Assessee stands allowed for statistical purposes

Bench: Shri N.K. Billaiya & Shri N.K. Choudhryassessment Year: 2014-15

trust in India for charitable purposes and consequently disallowed the said expenses of Rs.73,11,771/- incurred on Boarding and Lodging

VIDHYA DEVI,NOIDA vs. DCIT, CENTRAL CIRCLE, NOIDA

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Dey & Sh. M. Balaganeshassessment Year: 2012-13 Vidhya Devi Dcit C/O M/S. Rra Tax India, D- Vs Central Circle 28, South Extension, Part-I, Noida New Delhi Pan No.Asbpd0089B (Appellant) (Respondent) Appellant By Dr. Rakesh Gupta, Advocate Sh. Somil Agarwal, Advocate Sh. Deepesh Garg, Advocate Respondent By Sh. Daya Inder Singh Sidhu, Cit Dr Date Of Hearing: 07/02/2024 Date Of Pronouncement: 22/02/2024 Order Per Saktijit Dey,Vp: This Is An Appeal By The Assessee Arising Out Of Order Dated 23.10.2018 Of Learned Commissioner Of Income Tax (Appeals) – 4 (For Short “Cit(A)”), Kanpur For The Assessment Year 2012-13. 2. Though, The Assessee Has Raised Multiple Grounds Both On Jurisdictional Issue As Well As On Merits, However, At The Very Outset We Proceed To Decide The Jurisdictional Issue Raised In Ground No.1, As It Goes To The Root Of The Matter.

Disallowance on 16,52,931 account of : (1) Addition on account of capital 6,00,000 gain ( As discussed in Para5) (2) Addition on account of 8,78,038 unexplained gift (As discussed in Para6) (3) Addition on account of 1,20,00,000 unexplained jewellery as discussed in para 7 (4) Addition on account of house

SHRI RAM SHARNAM SABHA REGD.,PANIPAT vs. ITO(E), AMBALA

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

Bench: Shri Kul Bharat[Assessment Year : 2016-17] Shri Ram Sharnam Sabha Regd., Vs Ito(E), 588, Model Town, Panipat, Ambala, Haryana-122001. Haryana. Pan-Aaats4962K Appellant Respondent Appellant By Shri Shailendra Bajaj, Ca & Shri R.R.Maurya, Adv. Respondent By Shri Sanjay Kumar, Sr.Dr Date Of Hearing 22.02.2022 Date Of Pronouncement 12.04.2022 Order Per Kul Bharat, Jm : This Appeal Filed By The Assessee For The Assessment Year 2016-17 Is Directed Against The Order Of Ld. Cit(A), Karnal Dated 24.09.2019. The Assessee Has Raised Following Grounds Of Appeal:-

disallowed by the assessing authority. He contended that the AO did not accept the contention of the assessee and wrongly applied ratio of judgement of the Hon’ble Supreme Court rendered in the case of CIT vs Nagpur Hotel Owner’s Association 247 ITR 201 (SC). Ld. Counsel for the assessee submitted that the submissions of the assessee were