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

charitable or religious purposes outside India. It was further held that the words "in India" appearing in section ll(l)(a) and the words "outside India" appearing in section 11(l)(c) qualified the word "applied" appearing in these provisions and not the words "said purposes." 8. Thus, it is well settled law that the expenditure incurred by the trust

DCIT (EXEMPTIONS), CIRCLE 1(1), HYDERABAD vs. NATIONAL INSTITUTE OF RURAL DEVELOPMENT AND PANCHAYATI RAJ, HYDERABAD

In the result, both the appeal filed by the Revenue and cross- objection filed by the assessee are dismissed

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

charitable trust or institution registered under Section 12A of the Income-tax Act, 1961 and is eligible for claiming exemption under Section 11 of the Income-tax Act. The assessee further submitted that, although it has not furnished its return of income on or before the due date provided under Section 139(1) of the Act, but has filed

PRATHIMA EDUCATIONAL SOCIETY,HYDERABAD vs. ACIT (EXEMPTIONS) CIRCLE-1(1), HYDERABAD

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

Charitable Foundation Poona, that the amendment is prospective in nature. 3. Sec.11(6) introduced by Finance Act, 2014, AY 2015-16 reads as follows : Section 11(6) : " In this section where any income is required to be applied or accumulated or set apart for application, then, for such purposes the income shall be determined without any deduction or allowance

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)

11, 12, 12A, 12AA and 13 but the cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society under Section 12AB(4) of the Income Tax Act, 1961. The Ld. PCIT (Central) cancelled registration of the Society under Section 12AB

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)

11, 12, 12A, 12AA and 13 but the cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society under Section 12AB(4) of the Income Tax Act, 1961. The Ld. PCIT (Central) cancelled registration of the Society under Section 12AB

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)

11, 12, 12A, 12AA and 13 but the cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society under Section 12AB(4) of the Income Tax Act, 1961. The Ld. PCIT (Central) cancelled registration of the Society under Section 12AB

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

11, 12, 12A, 12AA and\n13 but the same may also cause prejudice/hardship to the\npersons in certain cases.\n23.\nComing back to the appellant's case and the reasons given\nby the Ld. PCIT (Central) for cancellation of registration of the\nappellant society under Section 12AB(4) of the Income Tax Act,\n1961. The Ld. PCIT (Central) cancelled registration

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)

11, 12, 12A, 12AA and 13 but the same may also cause prejudice/hardship to the persons in certain cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society under Section 12AB(4) of the Income Tax Act, 1961. The Ld. PCIT (Central) cancelled registration

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 objectives and is therefore not entitled to exemption. 6. In view of the foregoing, it is evident that the assessee society engaged in collection of unaccounted capitation fees, failed to maintain proper books of account and misrepresented actual fee collections. The society’s core objective is providing educational relief and as per elaborate discussion made above, excess fee collected

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 objectives and is therefore not entitled to exemption. 6. In view of the foregoing, it is evident that the assessee society engaged in collection of unaccounted capitation fees, failed to maintain proper books of account and misrepresented actual fee collections. The society’s core objective is providing educational relief and as per elaborate discussion made above, excess fee collected

AMEENAMMA CHARITBLE TRUST,ANANTAPUR vs. ITO, (EXEMPTION) WARD-TIRUPATI, TIRUPATI

In the result, appeal filed by the assessee Trust is partly allowed in terms of our aforesaid observations

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1841/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Ameenamma Charitable Vs. Income Tax Officer Trust, (Exemption) Ward – Anantapur. Tirupati. Pan: Aaeta7403P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ka Sai Prasad, Ca राज" व "ारा/Revenue By: Shri K Vamsi Krishna, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Trust Is Directed Against The Order Passed By The Additional/Joint Commissioner Of Income Tax (Appeals)-1, Chennai, Dated 03/10/2025, Which In Turn Arises From The Order Passed By The Income Tax Officer, Exemption Ward, Tirupati (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 14/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

11,78,000/- admitted as donations were treated as anonymous donations u/s 115BBC was rightly made. Considering the above facts addition made by the AO is upheld and appeal of the assessee is dismissed. Conclusion: In the result, the appeal is dismissed.” 6 Ameenamma Charitable Trust vs. ITO 6. The assessee Trust aggrieved with the order

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)

sections 11 and 12. These two provisions and few other provisions are competent enough to tackle firmly a defaulter of philanthropic application of income or funds of the trust. The other adverse side of cancellation is that on refusal of registration the entire receipts shall be subject to assessment without granting benefit of section 11 and section 12 to assess

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)

sections 11 and 12. These two provisions and few other provisions are competent enough to tackle firmly a defaulter of philanthropic application of income or funds of the trust. The other adverse side of cancellation is that on refusal of registration the entire receipts shall be subject to assessment without granting benefit of section 11 and section 12 to assess

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)

11 or 12 and there will be no occasion to the Assessing Officer to invoke or apply section 13 in his case. This position would not only be contrary to the persons in certain cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society

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)

11 or 12 and there will be no occasion to the Assessing Officer to invoke or apply section 13 in his case. This position would not only be contrary to the persons in certain cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society

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)

11, 12, 12A, 12AA and 13 but the same may also cause prejudice/hardship to the persons in certain cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society under Section 12AB(4) of the Income Tax Act, 1961. The Ld. PCIT (Central) cancelled registration

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

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

11, 12, 12A, 12AA and 13 but the same may also cause prejudice/hardship to the persons in certain cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society under Section 12AB(4) of the Income Tax Act, 1961. The Ld. PCIT (Central) cancelled registration

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)

11, 12, 12A, 12AA and persons in certain cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society under Section 12AB(4) of the Income Tax Act, 1961. The Ld. PCIT (Central) cancelled registration of the Society under Section 12AB

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

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

11, 12, 12A, 12AA and persons in certain cases. 23. Coming back to the appellant's case and the reasons given by the Ld. PCIT (Central) for cancellation of registration of the appellant society under Section 12AB(4) of the Income Tax Act, 1961. The Ld. PCIT (Central) cancelled registration of the Society under Section 12AB