SARASWATHI AMMAL EDUCATIONAL AND CHARITABLE TRUST,CHENNAI vs. ACIT CENTRE CIRCLE II, NOIDA

Appeals are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Charitable Trust Vs. ACIT result of the search, but also in respect of all matters relevant for the purposes of any investigation connected with any proceeding under the Indian Income- tax Act, 1922 (11 of 1922 ), or under this Act. (4A) Where any books of account, other documents, money, bullion, jewellery or other valuable article or thing

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. SARASWATI AMMAL EDUCATION AND CHARITABLE TRUST, CHENNAI

Appeals are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Charitable Trust Vs. ACIT result of the search, but also in respect of all matters relevant for the purposes of any investigation connected with any proceeding under the Indian Income- tax Act, 1922 (11 of 1922 ), or under this Act. (4A) Where any books of account, other documents, money, bullion, jewellery or other valuable article or thing

NATASHA CHOPRA,NEW DELHI vs. DCIT, CIRCLE-16(1), DELHI

Appeals are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Charitable Trust Vs. ACIT result of the search, but also in respect of all matters relevant for the purposes of any investigation connected with any proceeding under the Indian Income- tax Act, 1922 (11 of 1922 ), or under this Act. (4A) Where any books of account, other documents, money, bullion, jewellery or other valuable article or thing

NATASHA CHOPRA,NEW DELHI vs. DCIT, CIRCLE- 16(1), DELHI

Appeals are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Charitable Trust Vs. ACIT result of the search, but also in respect of all matters relevant for the purposes of any investigation connected with any proceeding under the Indian Income- tax Act, 1922 (11 of 1922 ), or under this Act. (4A) Where any books of account, other documents, money, bullion, jewellery or other valuable article or thing

JINDAL CHARITABLE SOCIETY,DELHI vs. PR. COMMISSIONER OF INCOME TAX(CENTRAL)-3, DELHI

In the result, the assessees‟ appeals are allowed

Bench: Shri C. N. Prasad & Shri M. Balaganeshlala Sher Singh Memorial Vs. Pcit(Central)-3, Jeevan Vigyan Trust Society, Jhandewalan, New Plot No. 18, Sector-22, Phase-1, Delhi Dwarka, Delhi-110075 (Appellant) (Respondent) Pan: Aaaal2241H Jindal Charitable Society, Vs. Pcit(Central)-3, Ps-2, C-3, Block, Phase-Ii, Jhandewalan, New Ashok Vihar, Delhi- 110052 Delhi (Appellant) (Respondent) Pan: Aaatj0588L Florence Nighingale Vs. Pcit(Central)-3, Educational Society, Jhandewalan, New Sector-16B, Phase-I, Haf Delhi Pocket-A, Sector-22, Delhi- 110075 (Appellant) (Respondent) Pan: Aaaaf1097R

search and seizure operation revealed the modus operandi of Mother's Pride and Presidium group of schools managed by Smt Sudha Gupta and Shri Devendra Gupta and Prudence group of schools managed by Sri G.S. Matharoo in systematic tax evasion i.e. raising funds from public through cash and cheque, siphoning of funds from trusts/ societies for personal use and unexplained

LALA SHER SINGH MEMORIAL JEEVAN VIGYAN TRUST SOCIETY,DELHI vs. PCIT (CENTRAL)-3, JHANDEWALAN NEW DELHI, DELHI

In the result, the assessees‟ appeals are allowed

Bench: Shri C. N. Prasad & Shri M. Balaganeshlala Sher Singh Memorial Vs. Pcit(Central)-3, Jeevan Vigyan Trust Society, Jhandewalan, New Plot No. 18, Sector-22, Phase-1, Delhi Dwarka, Delhi-110075 (Appellant) (Respondent) Pan: Aaaal2241H Jindal Charitable Society, Vs. Pcit(Central)-3, Ps-2, C-3, Block, Phase-Ii, Jhandewalan, New Ashok Vihar, Delhi- 110052 Delhi (Appellant) (Respondent) Pan: Aaatj0588L Florence Nighingale Vs. Pcit(Central)-3, Educational Society, Jhandewalan, New Sector-16B, Phase-I, Haf Delhi Pocket-A, Sector-22, Delhi- 110075 (Appellant) (Respondent) Pan: Aaaaf1097R

search and seizure operation revealed the modus operandi of Mother's Pride and Presidium group of schools managed by Smt Sudha Gupta and Shri Devendra Gupta and Prudence group of schools managed by Sri G.S. Matharoo in systematic tax evasion i.e. raising funds from public through cash and cheque, siphoning of funds from trusts/ societies for personal use and unexplained

FLORENCE NIGHTINGALE EDUCATIONAL SOCIETY,DELHI vs. PR. COMMISSIONER OF INCOME TAX(CENTRAL)-3, DELHI

In the result, the assessees‟ appeals are allowed

Bench: Shri C. N. Prasad & Shri M. Balaganeshlala Sher Singh Memorial Vs. Pcit(Central)-3, Jeevan Vigyan Trust Society, Jhandewalan, New Plot No. 18, Sector-22, Phase-1, Delhi Dwarka, Delhi-110075 (Appellant) (Respondent) Pan: Aaaal2241H Jindal Charitable Society, Vs. Pcit(Central)-3, Ps-2, C-3, Block, Phase-Ii, Jhandewalan, New Ashok Vihar, Delhi- 110052 Delhi (Appellant) (Respondent) Pan: Aaatj0588L Florence Nighingale Vs. Pcit(Central)-3, Educational Society, Jhandewalan, New Sector-16B, Phase-I, Haf Delhi Pocket-A, Sector-22, Delhi- 110075 (Appellant) (Respondent) Pan: Aaaaf1097R

search and seizure operation revealed the modus operandi of Mother's Pride and Presidium group of schools managed by Smt Sudha Gupta and Shri Devendra Gupta and Prudence group of schools managed by Sri G.S. Matharoo in systematic tax evasion i.e. raising funds from public through cash and cheque, siphoning of funds from trusts/ societies for personal use and unexplained

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE -05 , DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

Charitable Trust v. ACIT vi) 47 DTR 225 (Del) ITO vs. Purvi Fabrics & Textures (P) Ltd. 4. No addition can be made on the basis of self serving report of inspector 4. No addition can be made on the basis of self serving report of inspector 4. 4. No addition can be made on the basis of self serving report

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

Charitable Trust v. ACIT vi) 47 DTR 225 (Del) ITO vs. Purvi Fabrics & Textures (P) Ltd. 4. No addition can be made on the basis of self serving report of inspector 4. No addition can be made on the basis of self serving report of inspector 4. 4. No addition can be made on the basis of self serving report

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

Charitable Trust v. ACIT vi) 47 DTR 225 (Del) ITO vs. Purvi Fabrics & Textures (P) Ltd. 4. No addition can be made on the basis of self serving report of inspector 4. No addition can be made on the basis of self serving report of inspector 4. 4. No addition can be made on the basis of self serving report

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

In the result, the appeal of the Assessee is allowed

seizure operation under section 132 of the Act was\nconducted on 11-07-2023 in the case of PTC group companies. A\nconsequential search was also carried out in the case of the Assessee Society.\nThe claim of the Assessee is that no incriminating material or evidence was\nfound during the course of the search action on the Assessee Society

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 registered u/s 12A of the Act. The main objective of the trust was to promote the education, welfare activities and health consciousness among the society for the use of general public having motto as ‘Co-existence of all faiths as one race’ for enhancement of education, welfare of humanities and good health. A search and seizure

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 registered u/s 12A of the Act. The main objective of the trust was to promote the education, welfare activities and health consciousness among the society for the use of general public having motto as ‘Co-existence of all faiths as one race’ for enhancement of education, welfare of humanities and good health. A search and seizure

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.

search and seizure operation. As discussed earlier, the only incriminating material referred to in the satisfaction note is the trust deed of PGP charitable

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE- 05, DELHI

Charitable Trust v.\nACIT\n47 DTR 225 (Del) ITO vs. Purvi Fabrics & Textures (P) Ltd.\n4. No addition can be made on the basis of self serving report of inspector\nof investigation wing particularly when the assessee was not confronted\nwith the inspector report and during the assessment proceedings replies\nwere filed before the AO by most of the parties

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

Charitable Trust v.\nACIT\n47 DTR 225 (Del) ITO vs. Purvi Fabrics & Textures (P) Ltd.\n4. No addition can be made on the basis of self serving report of inspector\nof investigation wing particularly when the assessee was not confronted\nwith the inspector report and during the assessment proceedings replies\nwere filed before the AO by most of the parties

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

Charitable Trust v.\nACIT\n47 DTR 225 (Del) ITO vs. Purvi Fabrics & Textures (P) Ltd.\n4. No addition can be made on the basis of self serving report of inspector\nof investigation wing particularly when the assessee was not confronted\nwith the inspector report and during the assessment proceedings replies\nwere filed before the AO by most of the parties

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

Charitable Trust v.\nACIT\n47 DTR 225 (Del) ITO vs. Purvi Fabrics & Textures (P) Ltd.\n4. No addition can be made on the basis of self serving report of inspector\nof investigation wing particularly when the assessee was not confronted\nwith the inspector report and during the assessment proceedings replies\nwere filed before the AO by most of the parties