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

unexplained investments. The cases belonging to Smt Sudha Gupta and Shri Devendra Gupta group including the assessee were centralized to Central Circle 29 from Circle (Exemptions) 1(1), Delhi vide order passed under Section 127 of the Act dated 15-11-2022. The learned assessing officer i.e. Central Circle 29 Delhi was satisfied that the assessee Lala Sher Singh Memorial

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

unexplained investments. The cases belonging to Smt Sudha Gupta and Shri Devendra Gupta group including the assessee were centralized to Central Circle 29 from Circle (Exemptions) 1(1), Delhi vide order passed under Section 127 of the Act dated 15-11-2022. The learned assessing officer i.e. Central Circle 29 Delhi was satisfied that the assessee Lala Sher Singh Memorial

ITO (E), NEW DELHI vs. BHAI HOSPITAL TRUST, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. C. M. Garg & Sh. N.K. Billaiyaassessment Year: 2007-08 Ito (E) Bhai Hospital Trust Trust Ward-Iii Vs 55, Hanuman Road, Laxmi Nagar Distt. Centre Connaught Place, New Delhi New Delhi-1100001 Pan No.Aaatb0492M (Appellant) (Respondent)

charitable (i) activities as professed in the trust deed and as envisaged in the grant of registration u/s. 12A in terms of section 2(15); and section 11, 12 & 13 of the I.T. Act. Whether the shares of RLL of Rs.58,48,281/- held as investment (ii) does not represent violation of section 11(5) read with section

IILM FOUNDAION,NEW DELHI vs. ADIT (EXEMPTION), NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

investment pattern or use of the trust property for the benefit of the settlor, etc., contained in section 13(1)(c) and (d) of that Act, the said rate will not apply to the business profits of such trusts which are otherwise chargeable to tax. In other words, where such a trust contravenes the provisions of section

ADIT(E), NEW DELHI vs. M/S. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

investment pattern or use of the trust property for the benefit of the settlor, etc., contained in section 13(1)(c) and (d) of that Act, the said rate will not apply to the business profits of such trusts which are otherwise chargeable to tax. In other words, where such a trust contravenes the provisions of section

ADIT (E), NEW DELHI vs. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

investment pattern or use of the trust property for the benefit of the settlor, etc., contained in section 13(1)(c) and (d) of that Act, the said rate will not apply to the business profits of such trusts which are otherwise chargeable to tax. In other words, where such a trust contravenes the provisions of section

ITO (E), NEW DELHI vs. M/S. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

investment pattern or use of the trust property for the benefit of the settlor, etc., contained in section 13(1)(c) and (d) of that Act, the said rate will not apply to the business profits of such trusts which are otherwise chargeable to tax. In other words, where such a trust contravenes the provisions of section

ADIT(E), NEW DELHI vs. M/S. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

investment pattern or use of the trust property for the benefit of the settlor, etc., contained in section 13(1)(c) and (d) of that Act, the said rate will not apply to the business profits of such trusts which are otherwise chargeable to tax. In other words, where such a trust contravenes the provisions of section

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MEERUT, INCOME TAX OFFICE, MEERUT vs. UMALOK CHARITABLE TRUST, MEERUT

In the result, impugned order is upheld and appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1644/िद"ी/2024(िन.व. 2011-12) Deputy Commissioner Of Income Tax, Central Circle, Aayakar Bhawan, Near Bhainsali Ground, ...... अपीलाथ"/Appellant Meerut, Uttar Pradesh 250001 बनाम Vs. Umalok Charitable Trust, C-111, Samart Place, Garh Road, Meerut, ..... "ितवादी/Respondent Uttar Pradesh 250004 Pan: Aaatu-1532-F अपीलाथ" "ारा/Appellant By : Shri Dayainder Singh Sidhu, Cit(Dr) "ितवादी"ारा/Respondent By : Shri Kalrav Mehrotra, Advocate सुनवाई क" ितिथ/ Date Of Hearing : 24/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 24/07/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-3, Noida [In Short ‘The Cit(A)’] Dated 14.02.2024, For Assessment Year 2011-12. 2. The Revenue In Appeal Has Primarily Assailed The Order Of Cit(A) On Two Counts:- (I) Deleting The Addition Of Rs.2,11,00,000/- Made On Account Of Unexplained Advances; & (Ii) Deleting The Disallowance Of Exemption Claimed By The Assessee U/S.10(23C)Of The Act Rs.84,22,244/-.

Charitable Trust in their individual capacity and not on behalf of the assessee trust. Hence, the investment made by the trustee cannot be considered as source of investment by the assessee trust. 3.1. In respect of disallowance of assessee’s claim of exemption u/s.10(23)(c) of the Act, the ld. DR submits that a perusal of Registration Certificate

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 purposes. Further, the Trustees also denied of having any role in the Trust. e) During the search, the statement of Mr Man Singh, Mr Raghavendra Sharma and Mr Nishant Maheshwari, current Trustee, they categorically denied having any role in the activities of the Trust. Rather, they aditted that on the request of Shri Yadav Singh, their names are associated

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 purposes. Further, the Trustees also denied of having any role in the Trust. e) During the search, the statement of Mr Man Singh, Mr Raghavendra Sharma and Mr Nishant Maheshwari, current Trustee, they categorically denied having any role in the activities of the Trust. Rather, they aditted that on the request of Shri Yadav Singh, their names are associated

DCIT CENTRAL CIRCLE-06, NEW DELHI vs. SANTOSH TRUST, NEW DELHI

unexplained money under Section 69A r.w.s 115BBE in the\nabsence of corroborative evidence to justify the source of such deposits\nwhich was in turn deleted by the Ld. CIT(A).\n6.\nBefore the Ld. CIT(A) the assessee submitted the following in\nsupport of the source of SBN i.e. the demonetization currency:\npage 5\nITA No.1427/Del/2023 & CO 58/Del/2023\nSantosh Trust

RAGHAV KUMAR,DELHI vs. ACIT CENTRAL CIRCLE 29, NEW DELHI

In the result, the appeal filed by the assessee being ITA

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

unexplained investment and income thereon is merely a figment of imagination based on unfounded interpretation of vague and uncorroborated whatsapp chat and as such in absence of any incriminating material, the assumption of jurisdiction u/s 153C is dehors of valid basis and may kindly be quashed. 3.9 Reference is made to following judicial precedents: i. DCIT vs. Sunil Kumar Sharma

RAGHAV KUMAR,NEW DELHI vs. ACIT CENTRAL CIRCLE-29, NEW DELHI

In the result, the appeal filed by the assessee being ITA

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

unexplained investment and income thereon is merely a figment of imagination based on unfounded interpretation of vague and uncorroborated whatsapp chat and as such in absence of any incriminating material, the assumption of jurisdiction u/s 153C is dehors of valid basis and may kindly be quashed. 3.9 Reference is made to following judicial precedents: i. DCIT vs. Sunil Kumar Sharma

VIDHYA DEVI,NOIDA vs. DCIT, CENTRAL CIRCLE, NOIDA

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Dey & Sh. M. Balaganeshassessment Year: 2012-13 Vidhya Devi Dcit C/O M/S. Rra Tax India, D- Vs Central Circle 28, South Extension, Part-I, Noida New Delhi Pan No.Asbpd0089B (Appellant) (Respondent) Appellant By Dr. Rakesh Gupta, Advocate Sh. Somil Agarwal, Advocate Sh. Deepesh Garg, Advocate Respondent By Sh. Daya Inder Singh Sidhu, Cit Dr Date Of Hearing: 07/02/2024 Date Of Pronouncement: 22/02/2024 Order Per Saktijit Dey,Vp: This Is An Appeal By The Assessee Arising Out Of Order Dated 23.10.2018 Of Learned Commissioner Of Income Tax (Appeals) – 4 (For Short “Cit(A)”), Kanpur For The Assessment Year 2012-13. 2. Though, The Assessee Has Raised Multiple Grounds Both On Jurisdictional Issue As Well As On Merits, However, At The Very Outset We Proceed To Decide The Jurisdictional Issue Raised In Ground No.1, As It Goes To The Root Of The Matter.

unexplained jewellery as discussed in para 7 (4) Addition on account of house 5,07,036 hold expenses (para 8) (5) Total income Or Say Rs.63,06,628/- 5. Assessee challenged the assessment order both on jurisdictional issue as well as on merits. However, learned First Appellate Authority did not find merit in the submissions of the assessee hence, upheld

ACIT, NEW DELHI vs. M/S. MAHARAJI EDUCATION TRUST, GHAZIABAD

The appeal are dismissed

Bench: Shri Kuldip Singh & Shri Prashant Maharishi(Through Video Conferencing)

charitable trust carrying on activities in the field of education. It is a part of Santosh Group, which is also engaged in the field of education in Medical, Dental, Para-medical and other courses. For AY 2007-08, assessee filed its return of income on 31st October, 2007 4. stating that it has excess of expenditure over income amounting

KUSUM LATA,NOIDA vs. DCIT, CENTRAL CIRCLE , NOIDA

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

Charitable Trust in which the assessee is a trustee were found and seized from the residential premises of Sh. Sudhanshu Rathi on 27/11/2014, which were marked as Annexure LP-1. The contents of the above said seized Annexures establish the fact that assessee’s husband through his family members had had invested a huge amount of unaccounted money in acquisition

KUSUM LATA,NOIDA vs. DCIT, CENTRAL CIRCLE , NOIDA

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

Charitable Trust in which the assessee is a trustee were found and seized from the residential premises of Sh. Sudhanshu Rathi on 27/11/2014, which were marked as Annexure LP-1. The contents of the above said seized Annexures establish the fact that assessee’s husband through his family members had had invested a huge amount of unaccounted money in acquisition