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, 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 hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating to the allegation that such receipts belonged to assessee trust. Therefore, as per Section 292C/134(4) and Section 132

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 hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating to the allegation that such receipts belonged to assessee trust. Therefore, as per Section 292C/134(4) and Section 132

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 hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating to the allegation that such receipts belonged to assessee trust. Therefore, as per Section 292C/134(4) and Section 132

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 hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating to the allegation that such receipts belonged to assessee trust. Therefore, as per Section 292C/134(4) and Section 132

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

Appeals are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Charitable Trust Vs. ACIT hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating to the allegation that such receipts belonged to assessee trust. Therefore, as per Section 292C/134(4) and Section 132

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

Appeals are dismissed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Charitable Trust Vs. ACIT hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating to the allegation that such receipts belonged to assessee trust. Therefore, as per Section 292C/134(4) and Section 132

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

4) is not sustainable - judicial precedents In Kailashben Manharlal Chokshi vs. CTT: 328 ITR 411 (Guj) Stiree Ganesh Trading Company vs. CIT 257 CTR 159 (Jhar) CIT vs. Naresh Kumar Aggarwal: 369 ITR 171 (AP) CIT vs. Harjeev Aggarwal 241 Taxman 199 (Del) Chetnaben J. Shah vs. ITO: 288 CTR 579 (Guj) CIT v Smt. Jaya Lakshmi Ammal

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

4) is not sustainable - judicial precedents In Kailashben Manharlal Chokshi vs. CTT: 328 ITR 411 (Guj) Stiree Ganesh Trading Company vs. CIT 257 CTR 159 (Jhar) CIT vs. Naresh Kumar Aggarwal: 369 ITR 171 (AP) CIT vs. Harjeev Aggarwal 241 Taxman 199 (Del) Chetnaben J. Shah vs. ITO: 288 CTR 579 (Guj) CIT v Smt. Jaya Lakshmi Ammal

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

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

4) is not sustainable - judicial precedents In Kailashben Manharlal Chokshi vs. CTT: 328 ITR 411 (Guj) Stiree Ganesh Trading Company vs. CIT 257 CTR 159 (Jhar) CIT vs. Naresh Kumar Aggarwal: 369 ITR 171 (AP) CIT vs. Harjeev Aggarwal 241 Taxman 199 (Del) Chetnaben J. Shah vs. ITO: 288 CTR 579 (Guj) CIT v Smt. Jaya Lakshmi Ammal

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

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganesh

charitable purpose under section 2(15) of the Act. The society was duly granted registration under section 12AA of the Act on 25-08-2009 by the Commissioner of Income Tax, Ghaziabad, which was further granted registration under section 12AB of the Act on 5-4-2022 for assessment years 2022-23 to 2026-27 in accordance with the amended

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

4) of the Act by retrospectively cancelling the assessee‟s registration earlier granted under section 12AA of the Act. The assessee is an educational society duly registered under section 12AA of the Act and enjoying exemption under section 80G of the Act. The assessee society operates under the name of „Prudence School‟ in Ashok Vihar, New Delhi

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

4) of the Act by retrospectively cancelling the assessee‟s registration earlier granted under section 12AA of the Act. The assessee is an educational society duly registered under section 12AA of the Act and enjoying exemption under section 80G of the Act. The assessee society operates under the name of „Prudence School‟ in Ashok Vihar, New Delhi

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

4) of the Act by retrospectively cancelling the assessee‟s registration earlier granted under section 12AA of the Act. The assessee is an educational society duly registered under section 12AA of the Act and enjoying exemption under section 80G of the Act. The assessee society operates under the name of „Prudence School‟ in Ashok Vihar, New Delhi

LAKHMI CHAND CHARITABLE SOCIETY,NEW DELHI vs. PCIT CENTRAL 3, NEW DELHI

Bench: Shri S. Rifaur Rahman & Ms.Madhumita Roylakhmi Chand Vs. Principal Commissioner Charitable Society, Of Income Tax, Central-3 Elephanta Lane, Behind Room No. 325, 3Rd Floor, Sector-10/6 Market, New Income Tax Building, E-3 Golak Dham, Sector-10, Ara Centre, Jhandewalan Dwarka, Extension, New Delhi - 110075 New Delhi - 110055

4) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) whereby and whereunder P a g e | 2 Lakhmi Chand Charitable Society Vs. Pr.CIT, Central-3 the registration of the appellant trust from Assessment Year 2015- 16 to Assessment Year 2021-22 has been cancelled. 2. The appellant, a charitable society, is running a school

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

Section 132(4A) of the Act, presumption should have been drawn against the said Sh. V. Mathiyalgan not against the Assessee trust and assessee has duly rebutted such presumption. 14. The Ld. Counsel has also taken us through the statements of Sh. V. Mathiyalgan recorded on oath u/s 131(1A) as well as 132(4) of the Income