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

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

25 Lakhmi Chand Charitable Society Vs. Pr.CIT, Central-3 class of cases pertaining to section 10, section 11, section 12, section 13A and section 138 of the Art and clause (b), to issue orders in writing for the exercise of 'their powers and perform all 'their functions by Additional Commissioners of Income tax or Joint Commissioners of Income

DCIT, NEW DELHI vs. M/S. BHARAT SANCHAR NIGAM LTD., NEW DELHI

In the result, assessee’s appeal is allowed to the extent as mentioned above on the preliminary issue and the departmental appeal is dismissed

Bench: Smt Diva Singh & Sh.J.S.Reddyi.T.A .No.-3304/Del/2010 (Assessment Year-2004-05) Bharat Sanchar Nigam Ltd., Vs Dcit, Corporate Office, Taxation Section, Circle-2(1), Room No.-398, First Floor, Bharat Sanchar Bhawan, C.R.Building, I.P.Estate, Janpath, New Delhi-1110001. New Delhi Pan-Aabcb5576G (Appellant) (Respondent)

Charitable Trust vs State of Haryana AIR [2003] SC 1648 and Oriental Insurance Company Ltd. vs Hansraj Bhai [2001] 5 SCL 175, it was submitted that it is well-settled that in relation to the same subject matter, if different words/terminology of different import are used in the same statute then there is a presumption that they are not used

BHARAT SANCHAR NIGAM LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, assessee’s appeal is allowed to the extent as mentioned above on the preliminary issue and the departmental appeal is dismissed

Bench: Smt Diva Singh & Sh.J.S.Reddyi.T.A .No.-3304/Del/2010 (Assessment Year-2004-05) Bharat Sanchar Nigam Ltd., Vs Dcit, Corporate Office, Taxation Section, Circle-2(1), Room No.-398, First Floor, Bharat Sanchar Bhawan, C.R.Building, I.P.Estate, Janpath, New Delhi-1110001. New Delhi Pan-Aabcb5576G (Appellant) (Respondent)

Charitable Trust vs State of Haryana AIR [2003] SC 1648 and Oriental Insurance Company Ltd. vs Hansraj Bhai [2001] 5 SCL 175, it was submitted that it is well-settled that in relation to the same subject matter, if different words/terminology of different import are used in the same statute then there is a presumption that they are not used

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

Trust Society Jindal Charitable Society Florence Nighingale Educational Society PER M. BALAGANESH, A. M.: 1. The instant batch of 3 appeals of different assessees‟ is for AY 2024- 25. Identical issues are involved in all these appeals and hence they are taken up together and disposed of by this common order for the sake of convenience. The facts

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

Trust Society Jindal Charitable Society Florence Nighingale Educational Society PER M. BALAGANESH, A. M.: 1. The instant batch of 3 appeals of different assessees‟ is for AY 2024- 25. Identical issues are involved in all these appeals and hence they are taken up together and disposed of by this common order for the sake of convenience. The facts

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

Trust Society Jindal Charitable Society Florence Nighingale Educational Society PER M. BALAGANESH, A. M.: 1. The instant batch of 3 appeals of different assessees‟ is for AY 2024- 25. Identical issues are involved in all these appeals and hence they are taken up together and disposed of by this common order for the sake of convenience. The facts

DIRECTOR OF INCOME TAX (EXEMPTION) vs. NATIONAL ASSOCIATION OF SOFTWARE AND SERVICE COMPANIES (NASSCOM)

In the result the appeals are disposed of as above with no order as to

section 11(1), the permitted accumulation of 25% will also be calculated with reference to this income.” Relying on the circular, it was held by the Madras High Court that the expenditure incurred by a charitable trust

DIRECTOR OF INCOME TAX (EXEMPTION) vs. SERVICES COMPANIES

In the result the appeals are disposed of as above with no order as to

section 11(1), the permitted accumulation of 25% will also be calculated with reference to this income.” Relying on the circular, it was held by the Madras High Court that the expenditure incurred by a charitable trust

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, clauses 19 and 20 which permitted the trust to carry on any business and to borrow monies from banks, individuals, financial :1 institutions and business houses are not really the objects, but were clauses • stipulating the powers of the trustees. Having thus made a distinction between the objects and powers, the CIT (Appeals) proceeded to examine Section

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, clauses 19 and 20 which permitted the trust to carry on any business and to borrow monies from banks, individuals, financial :1 institutions and business houses are not really the objects, but were clauses • stipulating the powers of the trustees. Having thus made a distinction between the objects and powers, the CIT (Appeals) proceeded to examine Section

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, clauses 19 and 20 which permitted the trust to carry on any business and to borrow monies from banks, individuals, financial :1 institutions and business houses are not really the objects, but were clauses • stipulating the powers of the trustees. Having thus made a distinction between the objects and powers, the CIT (Appeals) proceeded to examine Section

CIT vs. MEHTA CHARITABLE PRAJNALAYA TRUST

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

charitable, clauses 19 and 20 which permitted the trust to carry on any business and to borrow monies from banks, individuals, financial :1 institutions and business houses are not really the objects, but were clauses • stipulating the powers of the trustees. Having thus made a distinction between the objects and powers, the CIT (Appeals) proceeded to examine Section

CIT vs. MEHTA CHARITABLE PRAJNALAYA TRUST

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

charitable, clauses 19 and 20 which permitted the trust to carry on any business and to borrow monies from banks, individuals, financial :1 institutions and business houses are not really the objects, but were clauses • stipulating the powers of the trustees. Having thus made a distinction between the objects and powers, the CIT (Appeals) proceeded to examine Section

COMMISSIONER OF INCOME TAX vs. MEHTA CHARITABLE PRAJNALAY TRUST

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

charitable, clauses 19 and 20 which permitted the trust to carry on any business and to borrow monies from banks, individuals, financial :1 institutions and business houses are not really the objects, but were clauses • stipulating the powers of the trustees. Having thus made a distinction between the objects and powers, the CIT (Appeals) proceeded to examine Section

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 his Interpretation/Remarks, which is reproduced at page 12 to 23 of the assessment order. 25. As per the provision of Section 292C of the Act, where any books of accounts or other documents, money, bullion jewellery or other valuable article or things are or is found in the possession or control of any person

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 his Interpretation/Remarks, which is reproduced at page 12 to 23 of the assessment order. 25. As per the provision of Section 292C of the Act, where any books of accounts or other documents, money, bullion jewellery or other valuable article or things are or is found in the possession or control of any person

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 his Interpretation/Remarks, which is reproduced at page 12 to 23 of the assessment order. 25. As per the provision of Section 292C of the Act, where any books of accounts or other documents, money, bullion jewellery or other valuable article or things are or is found in the possession or control of any person