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)

charitable activities, in our considered view, mere suspicion of certain violations, of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without any specified violations, simply cancelled registration of a trust

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)

charitable activities, in our considered view, mere suspicion of certain violations, of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without any specified violations, simply cancelled registration of a trust

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

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

charitable activities, in our considered view, mere suspicion of certain violations, including, specified violations cannot be a reason for cancellation of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without

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)

charitable activities, in our considered view, mere suspicion of certain violations, including, specified violations cannot be a reason for cancellation of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without

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)

charitable activities, in our considered view, mere suspicion of certain violations, including, specified violations cannot be a reason for cancellation of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without

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

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 activities, in our considered view, mere suspicion of certain violations, including, specified violations cannot be a reason for cancellation of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without

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 activities, in our considered view, mere suspicion of certain violations, including, specified violations cannot be a reason for cancellation of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without

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)

charitable activities, in our considered view, mere suspicion of certain violations, including, specified violations cannot be a reason for cancellation of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without

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)

charitable activities, in our considered view, mere suspicion of certain violations, including, specified violations cannot be a reason for cancellation of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without

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)

4) of the Act, by the Finance Act, 2022 w.e.f 01.04.2022 where registration or provisional registration of a trust or an institution has been granted u/s 12AA of the Act, as the case may be and subsequently, the Pr.CIT or Commissioner has noticed occurrence of one or more specified violations during any previous year or the Pr.CIT or Commissioner

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

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

charitable activities, in our considered view, mere suspicion of certain violations, including, specified violations cannot be a reason for cancellation of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without

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)

charitable activities, in our considered view, mere suspicion of certain violations, including, specified violations cannot be a reason for cancellation of registration of a trust under Section 12AB(4) of the Income Tax Act, 1961. In the present case, although there is no condition precedent for invoking provisions of Section 12AB(4) of the Act, the Ld. PCIT (Central), without

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

4) of the Act, by the Finance Act, 2022 w.e.f 01.04.2022 where registration or provisional registration of a trust or an institution has been granted u/s 12AA of the Act, as the case may be and subsequently, the Pr.CIT or Commissioner has noticed occurrence of one or more specified violations during any previous year or the Pr.CIT or Commissioner

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

4 of Section 92C, Clause (2) of Section 152, and Section 115A of the Act, submitted that wherever intended, the legislature has provided express provisions for barring a claim under Chapter VI-A, therefore, when there is no such express bar, the same cannot be read into the statute. He further referring to the argument of the learned senior counsel

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

4(3)(i): "(d) The exemption is restricted to such portion of the income as is in fact applied, or accumulated or set apart for application, to religious or charitable purposes within the taxable territories. The territorial limit of application of income -viz. the taxable territories - is as essential to secure exemption as the nature of the purpose - viz. religious

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:

Charitable Trust vs. ITO accumulation over and above the eligible 15% of the gross income amounting to Rs.6,74,111/-. The AO observed that in order to accumulate the amount in excess of 15% of the gross income, the Trust, claiming exemption under section 11 of the Act, needs to comply with the provisions of section

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

4) of the Act, by the Finance Act, 2022 w.e.f 01.04.2022 where registration or provisional registration of a trust or an institution has been granted u/s 12AA of the Act, as the case may be and subsequently, the Pr.CIT or Commissioner has noticed occurrence of one or more specified violations during any previous year or the Pr.CIT or Commissioner