SRI VENAKTESWARA SWAMY DEVASTANAM,,JAMALAPURAM vs. ITO., EXEMPTION WARD1- (3), HYDERABAD

In the result, both the appeals filed by the assessee are partly allowed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1002 & 1003/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2013-14 & 2016-17) Sri Venkateswara Swamy Vs. Income Tax Officer Devasthanam (Exemption), Ward 1(3) Jamalapuram Hyderabad Pan:Aamts2301Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate E Hari Babu राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 14/05/2025 घोषणा की तारीख/Pronouncement: 03/07/2025 आदेश/Order Per Vijay Pal Raothese Appeals Filed By The Assessee Are Directed Against Two Separate Orders, Both Dated 19/02/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys. 2013-14 & 2016-17. 2. There Is A Delay Of 160 Days In Filing The Present Appeals. The Assessee Has Filed An Application For Condonation Of Delay. The Learned Ar Of The Assessee Has Submitted That During The Pendency Of The Appeal Before The Learned Cit (A), The Assessee Filed A Writ Petition Before The Hon'Ble High Court For Issuing Directions To The Learned Cit (A) & The Hon'Ble High Court Was Pleased To Give Directions To The Learned Cit (A)

trust or endowments including Math/Temples/ Gurdwara/Waqf/Churches etc., or other placed of public religious worship. Therefore, the income of such body which is constituted Page 17 of 37 ITA Nos 1002 and 1003 of 2024 Sri Venkateswara Swamy Devastanam by the Central or State govt, to administer interalia Endowment Temples is exempt u/s 10(23BBA) and not the income

ACIT., EXEMPTIONS CIRCLE-1(1), HYDERABAD vs. PHARMACEUTICALS EXPORT PROMOTION COUNCIL OF INDIA, HYDERABAD

In the result, the appeal of Revenue is allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2016-17 The Assistant Commissioner Vs. Pharmaceuticals Export Of Income Tax, Promotion Council Of India, Exemptions, Circle – 1(1), Hyderabad. Hyderabad. Pan : Aadcp4643C (Appellant) (Respondent) Assessee By: Shri Rv. Chalam, C.A. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 11.02.2025

10 charitable trust is to be included in the total income as is in fact applied to religious or charitable purposes outside the taxable territories. In other words, the Revenue confines the right of exemption to only such trusts as are administered for the benefit of the public of India and does not extend it to foreign charities. Two exceptional

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash expenditure and the unaccounted cash found and seized from

CMR EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash expenditure and the unaccounted cash found and seized from

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Cement Diary from the premises of Shri Empally Raghunath Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash

K M R EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Cement Diary from the premises of Shri Empally Raghunath Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash

MARUTHI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash expenditure and the unaccounted cash found and seized from

MARRI EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Cement Diary from the premises of Shri Empally Raghunath Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10 AABTM7610H- MALLA REDDY EDUCATIONAL SOCIETY A.Y. 2019-20 ITBA/COM/F/17/2024-25/1075093075(1) and hence by virtue of powers vested in me u/s 12AB of the Act, the registration granted u/s 12AA of the Act vide proceedings in F.NO.DIT(E)/12A/HYD/139(03)/07-08 dtd 10.08.2007 is hereby cancelled wef A.Y 2019-2020 with all attendant consequences including the invocation of the provisions

MALLA REDDY EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

10 AABTM7610H- MALLA REDDY EDUCATIONAL SOCIETY A.Y. 2019-20 ITBA/COM/F/17/2024-25/1075093075(1) and hence by virtue of powers vested in me u/s 12AB of the Act, the registration granted u/s 12AA of the Act vide proceedings in F.NO.DIT(E)/12A/HYD/139(03)/07-08 dtd 10.08.2007 is hereby cancelled wef A.Y 2019-2020 with all attendant consequences including the invocation of the provisions

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Cement Diary from the premises of Shri Empally Raghunath Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash

CMR TECHNICAL EDUCATION SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Cement Diary from the premises of Shri Empally Raghunath Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash

CHANDRAMMA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash expenditure and the unaccounted cash found and seized from

CHANDRAMMA EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

10. The Ld. PCIT (Central) further observed that the documents found during the course of search in the form of Birla Sakthi Reddy reveals that during the period from 24.03.2019 to 31.03.2019 cash of Rs.2,44,69,000/- was spent not for the purpose/objects of the society. Further, the above cash expenditure and the unaccounted cash found and seized from

CMR ENGINEERING EDUCATIONAL SOCIETY,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(1), HYDERABAD

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

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

charitable in nature, and it is continuing its activities in accordance with its objects, registration of trust u/s 12AA(4) of the Act on the ground of activities being carried out are not genuine and are not being carried out as per the terms of the registration of the trust or society cannot be cancelled. We, find that Coordinate Bench

NETENRICH TECHNOLOGIES PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE - 5(1), HYDERABAD

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

Bench: SHRI MANJUNATHA G. (Accountant Member), SHRI K.NARASIMHA CHARY (Judicial Member)

charitable in nature, and it is continuing its activities in accordance with its objects, registration of trust u/s 12AA(4) of the Act on the ground of activities being carried out are not genuine and are not being carried out as per the terms of the registration of the trust or society cannot be cancelled. We, find that Coordinate Bench

RAVI RISHI EDUCATIONAL SOCIETY ,HYDERABAD vs. ACIT CENTRAL CIRCLE-2 (4), HYDERABAD

In the result, the solitary ground raised by the Revenue in the appeals are dismissed

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2017-18 Ravi Rishi Educational A.C.I.T. Society, Hyderabad Central Circle 2(4) Pan:Aaaar1952M Hyderabad (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Esthen N Hangal, Dr Date Of Hearing: 07/06/2022 Date Of Pronouncement: 19/07/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 21/04/2022 Of The Learned Cit (A)-12, Hyderabad Relating To A.Y.2017-18. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Aop & Registered U/S 12A Of The I.T. Act Vide Proceedings Of The Director Of Income Tax (Exemption) Hyderabad In F.No.Hqrs/I/15/12A/Dit(E) Dated 27.02.2003. The Assessee Filed Its Original Return Of Income For The A.Y 2017-18 On 06.11.2017 Admitting Total Income Of Rs.Nil. M/S. Ravi Rishi Educational Society Is Run By Close Family Members Mr.N.Rajababu, Mr.Ramesh Babu, Mrs. N. Sulochana, Mrs. N. Yashoda, Mrs. N.

charitable purposes as mandated by section 11 of the I.T. Act. The learned CIT (A) deleted the addition and Revenue is not in appeal before us, therefore, we are not concerned with the same. However, the Assessing Officer made addition of Rs.11,00,06,345/- as unexplained investment which has been sustained by the learned CIT (A) which

AGRICULTURAL MARKET COMMITTEE,NIRMAL vs. INCOME TAX OFFICER, WARD-2, NIRMAL

In the result, all the appeals under consideration are treated as allowed for statistical purposes

Bench: Shri V. Durga Rao

trust and nothing more. The Agricultural Marketing Acts provide for establishment of notified market areas/yards for purchase and sale of agricultural produce and livestock and for better regulation of such markets. The purpose of marketing legislation is to enable purchasers to get a fair price for the commodities by eliminating middlemen and provide a regulating market with facilities for correct

AGRICULTURAL MARKET COMMITTEE,SARANGAPUR vs. INCOME TAX OFFICER, WARD-1, NIRMAL

In the result, all the appeals under consideration are treated as allowed for statistical purposes

Bench: Shri V. Durga Rao

trust and nothing more. The Agricultural Marketing Acts provide for establishment of notified market areas/yards for purchase and sale of agricultural produce and livestock and for better regulation of such markets. The purpose of marketing legislation is to enable purchasers to get a fair price for the commodities by eliminating middlemen and provide a regulating market with facilities for correct