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

AB] or to any fund or institution or 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

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

1. That on facts and in law, the Ld. Principal Commissioner of Income Tax (Central)-3, Delhi ("Ld. PCIT") erred in passing the impugned order dated 30.12.2024 under Section 12A read with Sections 12AA and 12AB(4) of the Income-tax Act, 1961 ("the Act") sans lawful jurisdiction and in a pre-determined, arbitrary and mechanical manner by exclusively relying

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

1. That on facts and in law, the Ld. Principal Commissioner of Income Tax (Central)-3, Delhi ("Ld. PCIT") erred in passing the impugned order dated 30.12.2024 under Section 12A read with Sections 12AA and 12AB(4) of the Income-tax Act, 1961 ("the Act") sans lawful jurisdiction and in a pre-determined, arbitrary and mechanical manner by exclusively relying

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

1. That on facts and in law, the Ld. Principal Commissioner of Income Tax (Central)-3, Delhi ("Ld. PCIT") erred in passing the impugned order dated 30.12.2024 under Section 12A read with Sections 12AA and 12AB(4) of the Income-tax Act, 1961 ("the Act") sans lawful jurisdiction and in a pre-determined, arbitrary and mechanical manner by exclusively relying

DIVINE EDUCATIONAL AND CHARITABLE TRUST,DELHI vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL) - 3, DELHI

In the result, the assessees’ appeals are allowed

Charitable vs Principal (Central)-3 Trust, G-10, Pushkar Delhi Enclave, Paschim Vihar, Delhi PAN No.AAATNO218K (Appellant) (Respondent) Appellant by Sh. Rajeshwar Prasad Painuly, CA Respondent by Sh. Amit Jain, CIT DR Page 2 of 27 Date of Hearing 23/09/2025 Date of 26/11/2025 Pronouncement ORDER PER M. BALAGANESH, AM: These appeals of the different Assessees’ arise out of the order

NATHANEIL JUNIOR EDUCATION SOCIETY,DELHI vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL) - 3 , DELHI

In the result, the assessees’ appeals are allowed

Charitable vs Principal (Central)-3 Trust, G-10, Pushkar Delhi Enclave, Paschim Vihar, Delhi PAN No.AAATNO218K (Appellant) (Respondent) Appellant by Sh. Rajeshwar Prasad Painuly, CA Respondent by Sh. Amit Jain, CIT DR Page 2 of 27 Date of Hearing 23/09/2025 Date of 26/11/2025 Pronouncement ORDER PER M. BALAGANESH, AM: These appeals of the different Assessees’ arise out of the order

PRESIDIUM EDUCATIONAL & CHARITABLE TRUST,DELHI vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL) - 3 , DELHI

In the result, the assessees’ appeals are allowed

Charitable vs Principal (Central)-3 Trust, G-10, Pushkar Delhi Enclave, Paschim Vihar, Delhi PAN No.AAATNO218K (Appellant) (Respondent) Appellant by Sh. Rajeshwar Prasad Painuly, CA Respondent by Sh. Amit Jain, CIT DR Page 2 of 27 Date of Hearing 23/09/2025 Date of 26/11/2025 Pronouncement ORDER PER M. BALAGANESH, AM: These appeals of the different Assessees’ arise out of the order

SHRI NARENDRA CHARITABLE TRUST,DELHI vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL) - 3, DELHI

In the result, the assessees’ appeals are allowed

Charitable vs Principal (Central)-3 Trust, G-10, Pushkar Delhi Enclave, Paschim Vihar, Delhi PAN No.AAATNO218K (Appellant) (Respondent) Appellant by Sh. Rajeshwar Prasad Painuly, CA Respondent by Sh. Amit Jain, CIT DR Page 2 of 27 Date of Hearing 23/09/2025 Date of 26/11/2025 Pronouncement ORDER PER M. BALAGANESH, AM: These appeals of the different Assessees’ arise out of the order

ADARSH SHIV SHAKTI SHIKSHA SAMITI,DELHI vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL) - 3, DELHI

In the result, the assessees’ appeals are allowed

Charitable vs Principal (Central)-3 Trust, G-10, Pushkar Delhi Enclave, Paschim Vihar, Delhi PAN No.AAATNO218K (Appellant) (Respondent) Appellant by Sh. Rajeshwar Prasad Painuly, CA Respondent by Sh. Amit Jain, CIT DR Page 2 of 27 Date of Hearing 23/09/2025 Date of 26/11/2025 Pronouncement ORDER PER M. BALAGANESH, AM: These appeals of the different Assessees’ arise out of the order

SHAKUNTALAM EDUCATIONAL SOCIETY EAST DELHI,NEW DELHI vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL)- 3, DELHI

In the result, the assessees’ appeals are allowed

Charitable vs Principal (Central)-3 Trust, G-10, Pushkar Delhi Enclave, Paschim Vihar, Delhi PAN No.AAATNO218K (Appellant) (Respondent) Appellant by Sh. Rajeshwar Prasad Painuly, CA Respondent by Sh. Amit Jain, CIT DR Page 2 of 27 Date of Hearing 23/09/2025 Date of 26/11/2025 Pronouncement ORDER PER M. BALAGANESH, AM: These appeals of the different Assessees’ arise out of the order

MMTC LTD vs. DCIT, CIRCLE-5(1),,

In the result, the assessees’ appeals are allowed

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Charitable vs Principal (Central)-3 Trust, G-10, Pushkar Delhi Enclave, Paschim Vihar, Delhi PAN No.AAATNO218K (Appellant) (Respondent) Appellant by Sh. Rajeshwar Prasad Painuly, CA Respondent by Sh. Amit Jain, CIT DR Page 2 of 27 Date of Hearing 23/09/2025 Date of 26/11/2025 Pronouncement ORDER PER M. BALAGANESH, AM: These appeals of the different Assessees’ arise out of the order

HCL FOUNDATION,NEW DELHI vs. CIT(E), NEW DELHI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Amit Shukla & Shri Prashant Maharishi[Assessment Year: N/A.] Hcl Foundation, The Commissioner Of Income 806 – Siddharth, 96 – Nehru Place, Vs. Tax (Exemptions) New Delhi – 110 019. New Delhi. Pan: Aaath9728C (Appellant) (Respondent)

ab) of the Act. on the other. “ 3. Brief facts of the case shows that assessee is a charitable trust created on 01.07.2012 and registered u/s 12A read with section 12AA of the Act as per registration certificate dated 23.01.2012. On 16.09.2014, name of assessee/appellant trust was changed from ‘HCL Technologies Foundation’ to ‘HCL Foundation’. Assessee wanted to make certain

SAJAN KUMAR JAIN,DELHI vs. DCIT,CENTRAL CIRCLE-25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

ab)] of sub-section (1)] of section 12A.] [(3) Where a trust or an institution has been granted registration under clause (b) of sub- section (1) [or has obtained registration at any time under section 12A [as it stood before its amendment by the Finance (No.2) Act, 1996 (33 of 1996)]] and subsequently the [Principal Commissioner or] Commissioner is satisfied

ANAND KUMAR JAIN,FARIDABAD vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

ab)] of sub-section (1)] of section 12A.] [(3) Where a trust or an institution has been granted registration under clause (b) of sub- section (1) [or has obtained registration at any time under section 12A [as it stood before its amendment by the Finance (No.2) Act, 1996 (33 of 1996)]] and subsequently the [Principal Commissioner or] Commissioner is satisfied

ANAND JAIN HUF,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

ab)] of sub-section (1)] of section 12A.] [(3) Where a trust or an institution has been granted registration under clause (b) of sub- section (1) [or has obtained registration at any time under section 12A [as it stood before its amendment by the Finance (No.2) Act, 1996 (33 of 1996)]] and subsequently the [Principal Commissioner or] Commissioner is satisfied

ANAND KUMAR JAIN,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

ab)] of sub-section (1)] of section 12A.] [(3) Where a trust or an institution has been granted registration under clause (b) of sub- section (1) [or has obtained registration at any time under section 12A [as it stood before its amendment by the Finance (No.2) Act, 1996 (33 of 1996)]] and subsequently the [Principal Commissioner or] Commissioner is satisfied

ANAND JAIN HUF,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

ab)] of sub-section (1)] of section 12A.] [(3) Where a trust or an institution has been granted registration under clause (b) of sub- section (1) [or has obtained registration at any time under section 12A [as it stood before its amendment by the Finance (No.2) Act, 1996 (33 of 1996)]] and subsequently the [Principal Commissioner or] Commissioner is satisfied

ANAND KUMAR JAIN,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

ab)] of sub-section (1)] of section 12A.] [(3) Where a trust or an institution has been granted registration under clause (b) of sub- section (1) [or has obtained registration at any time under section 12A [as it stood before its amendment by the Finance (No.2) Act, 1996 (33 of 1996)]] and subsequently the [Principal Commissioner or] Commissioner is satisfied