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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, NOIDA, 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

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

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

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

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

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

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, NOIDA, NOIDA vs. SARASWATI AMMAL EDUCATION AND CHARITABLE TRUST, CHENNAI

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Charitable Trust, Chennai. During the search, various loose paper and documents were found and seized from the possession of Sh. V. Mathiyalgan. As per the A.O., these documents are related to SIMS, Hapur. A survey u/s 133A of the Act was also conducted in the case of SIMS, Hapur on 10/03/2017. During the survey operation on the SIMS, Hapur, neither

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

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Charitable Trust v. ACIT 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 of investigation wing particularly when the assessee was not confronted with the inspector report and during the assessment proceedings replies were filed before the AO by most of the parties

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

Charitable Trust v. ACIT 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 of investigation wing particularly when the assessee was not confronted with the inspector report and during the assessment proceedings replies were filed before the AO by most of the parties

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

seizure and survey operations no attempt should be made to obtain confession as to the undisclosed income. Any action on the contrary shall be viewed adversely Further, in respect of pending assessment proceedings also. Assessing officers should rely upon the evidences/materials gathered during the course of search/survey operations or thereafter while framing the relevant assessment orders." (emphasis supplied) The aforesaid

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

seizure and survey operations no attempt should be made to obtain confession as to the undisclosed income. Any action on the contrary shall be viewed adversely Further, in respect of pending assessment proceedings also. Assessing officers should rely upon the evidences/materials gathered during the course of search/survey operations or thereafter while framing the relevant assessment orders." (emphasis supplied) The aforesaid