COMMISSIONER OF INCOME TAX vs. M/S JAMNALAL BAJAJ FOUNDATION

trust or any university or other educational institution or any hospital or other medical institution referred to in sub-clause (iv) or sub-clause (v) or sub-clause (vi) or sub-clause (vi-a) of clause (23- C) of Section 10, shall not be treated as application of income for charitable or religious purposes, either during the period of accumulation

COMMISSIONER OF INCOME TAX vs. M/S JAMNALAL BAJAJ FOUNDATION

Bench: HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV,HON'BLE MR. JUSTICE YASHWANT VARMA

trust or any university or other educational institution or any hospital or other medical institution referred to in sub-clause (iv) or sub-clause (v) or sub-clause (vi) or sub-clause (vi-a) of clause (23- C) of Section 10, shall not be treated as application of income for charitable or religious purposes, either during the period of accumulation

MOOL CHAND KHAIRATI RAM TRUST vs. DIRECTOR OF INCOME TAX (EXEMPTIONS)

The appeal is disposed of

charitable or religious trust is exempt from taxation under the correlated provisions of sections 11, 12, 12A, 12AA and 13. Section

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

In the result, the appeal of the Assessee is allowed

charitable or religious trust running an educational institution or a\nmedical institution or a hospital, the exemption under section 11 or section 12 shall\nnot be denied in relation to any income, other than the income referred to in sub-\nsection (2) of section 12, by reason only that such trust has provided educational or\nmedical facilities to persons referred

BHAGWANT SINGH CHARITABLE TRUST,NEW DELHI vs. ACIT(EXEMPTION), CIRCLE-1(1), NEW DELHI

In the result, the appeal of the assessee is dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

section 12A. The appellant had submitted that the trust was approached by the “Riveridale Preparatory School Society” to provide managerial, technical, educational and co-cordial services including managerial experience, setting the amount of school if, recruitment of teaching and non teaching staff for running the proposed school against the consideration. It was also submitted that such services fall under clause

PATANJALI YOGPEETH (NYAS),DELHI vs. ADIT(EXEMPTION), NEW DELHI

Appeal is allowed

Bench: Shri I.C. Sudhir & Shri L. P. Sahu

charitable trust duly registered under section 12A vide order dated 14.03.2005 and is also duly approved under section 80G(5)(vi) of the Act vide

DCIT (EXEMPTION), UTTAR PRADESH vs. M/S. DIVYA YOG MANDIR TRUST, HARIDWAR

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

sections 11, 12A and 12A(a) of the Act. AO held the activities of the assessee trust not covered u/s 2(15) of the Act and declined the exemption u/s 11 of the Act. AO taxed the total income at Rs.52,76,05,600/- on the ground that the activities of the trust are not of charitable

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

Trust under section 12A was cancelled by the Commissioner of Income-tax, Amritsar ("CIT, Amritsar') by an order dated 31.12.2008 passed under section I2AA(3) of the Act, wherein it was held that the Appellant was involved in illegal kidney transplant and thus, the activities carried out by the Appellant ceased to be for charitable

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

12A read with Sections 12AA and 12AB(4) of the Act, without addressing or distinguishing the judicial precedents vide Heart Foundation of India v. Commissioner of Income Tax-Central, Pune (ITA No. 1524/Mum/2023 dated 12.07.2023) Lala Sher Singh Memorial Jeevan Vigyan Trust Society Jindal Charitable

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

12A read with Sections 12AA and 12AB(4) of the Act, without addressing or distinguishing the judicial precedents vide Heart Foundation of India v. Commissioner of Income Tax-Central, Pune (ITA No. 1524/Mum/2023 dated 12.07.2023) Lala Sher Singh Memorial Jeevan Vigyan Trust Society Jindal Charitable

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

12A read with Sections 12AA and 12AB(4) of the Act, without addressing or distinguishing the judicial precedents vide Heart Foundation of India v. Commissioner of Income Tax-Central, Pune (ITA No. 1524/Mum/2023 dated 12.07.2023) Lala Sher Singh Memorial Jeevan Vigyan Trust Society Jindal Charitable

DCIT (EXEMPTION), GHAZIABAD vs. M/S. DIVYA YOG MANDIR TRUST, HARIDWAR

In the result, appeal filed by the revenue is dismissed

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2013-14 Dcit(Exemptions), Divya Yog Mandir Trust, Room No. 105, 1St Floor, Kripalu Bagh, Cgo-Ii, Vs Kankhal, Kamla Nehru Nagar, Haridwar. Ghaziabad. (Pan: Aaatd1114E) Appellant Respondent Department By: Ms Nidhi Srivastava, C.I.T. Dr Assessee By: Shri Rohti Jain, Advocate Date Of Hearing: 29.07.2019 Date Of Pronouncement: 31.07.2019 O R D E R

12A in the status of a religious and charitable trust. Likewise the decision of Hon'ble Bombay High Court in the case of Rajneesh Foundation (supra) is not relevant as the said decision was rendered prior to introduction of proviso to section

ACIT (EXEMPTION), GHAZIABAD vs. M/S. DIVYA YOG MANDIR TRUST,, HARIDWAR

In the result, appeal filed by the revenue is dismissed

Bench: Shri H. S. Sidhu & Shri Prashant Maharishia Y 2010-11 Acit (Exemption) Vs Divya Yog Mandir Trust Circle, Cgo-1 Kripalu Bag, Hapur Road, Kankhal, Haridwar Ghaziabad (Pan Aaatd1114E) (Appellant) (Respondent)

12A in the status of a religious and charitable trust. Likewise the decision of Hon'ble Bombay High Court in the case of Rajneesh Foundation (supra) is not relevant as the said decision was rendered prior to introduction of proviso to section

ARYA SMAJ MODEL TOWN,DELHI vs. PCIT, CENTRAL -3, NEW DELHI

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

12A of the Act, which was granted to\nthe assessee on 4-6-1992 cannot be cancelled u/s 12AB (4) of the Act.\nFor understanding this issue, we will go through the section 12AB (4)\nof the Act, which reads as follows:\n\n\"12AB(4) Where resignation or provisional registration of a trust or an\ninstitution has been granted

SHREE KHATHU SHYAM JANGID BRAHMAN DHARAMSHALA,GURGAON vs. ITO(E) WARD, FARIDABAD

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

Bench: Shri C.M. Gargassessment Year: 2016-17 Shree Khathu Shyam Jangid Brahman Vs. Ito (E), Dharamshala, Ward, C/O Rra Taxindia, Faridabad. D-28, South Exension, Part I, New Delhi – 110 049. Pan: Aajts0636B (Appellant) (Respondent) Assessee By : Shri Somil Agarwal, Advocate & Shri Deepesh Garg, Advocate Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 07.06.2022 Date Of Pronouncement : 08.07.2022 Order

Trust vs. ITO, dated 22.02.2016, in ITA No.2515/Ahd/2015, submitted that the first proviso to sub-section (2) of section 12A was brought to the statute with retrospective effect with a view not to affect the genuine charitable

CIT vs. MEHTA CHARITABLE PRAJNALAYA TRUST

Inasmuch as all that is required is for the settler of the trust to declare that the

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.V.EASWAR

charitable trust existing for the benefit of the members of the public, that it was registered with the CIT under Section 12A

DIRECTOR OF INCOME TAX EXEMPTIONS vs. MEHTA CHARITABLE PRAJNALAY TRUST

Inasmuch as all that is required is for the settler of the trust to declare that the

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.V.EASWAR

charitable trust existing for the benefit of the members of the public, that it was registered with the CIT under Section 12A

CIT vs. MEHTA CHARITABLE PRAJNALAYA TRUST

Inasmuch as all that is required is for the settler of the trust to declare that the

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE R.V.EASWAR

charitable trust existing for the benefit of the members of the public, that it was registered with the CIT under Section 12A