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

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

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 Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee

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 Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee

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)

section 10 in order to grant exemption in respect of income arising to anybody or authority established, constituted or appointed under any enactment for the administration of such public religious or charitable trusts or endowments or societies for religious or charitable purposes. It is however, being made clear that the exemption would not apply to the income of such trust

SRI VENKATESWARA SWAMY DEVASTANAM,JAMALAPURAM vs. ITO., EXEMPTION WARD-1(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)

section 10 in order to grant exemption in respect of income arising to anybody or authority established, constituted or appointed under any enactment for the administration of such public religious or charitable trusts or endowments or societies for religious or charitable purposes. It is however, being made clear that the exemption would not apply to the income of such trust

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 Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee

ACIT,CIRCLE-13(1), HYDERABAD vs. M/S SURESH PRODUCTIONS PVT. LTD.,, HYDERABAD

Accordingly, the ground of the revenue is allowed

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

15-12-2004, which were utilized for other business purpose of the assessee. Thus, I hold that there is no direct nexus between the loan amount being utilized for the purpose of Windmill and hence, the AO was not justified in reducing the interest paid to Bank of Baroda, for the purpose of deduction u/s 80IA. The AO is directed

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)

Charitable Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee

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

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

Charitable Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee

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 Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee

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

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

Charitable Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee's claim of compliance to Government norms lacks merit

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 Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee's claim of compliance to Government norms lacks merit

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 Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee

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 Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee

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 Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee

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 Trust Vs. DCIT (Central) (2025) 173 Taxmann.com 577, Bangalore Tribunal. 15. Ms. U. Mini Chandran, learned CIT-DR for the Revenue, on the other hand, supporting the Order of the learned PCIT-Central submitted that, the seized material reveal fee packages exceeding government limits, with lump-sum tuition fees lacking clear bifurcation from ancillary charges. Further, the assessee