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)

trust under section 11. During the relevant assessment years, there is no such provision in the Act that in case return is not filed by charitable society 13 ITA Nos.1210 and 1211/Hyd/2025 & C.O. Nos.27 and 28/Hyd/2025 National Institute of Rural Development & Pranchayati Raj under section 139(4A), then its income cannot be computed in accordance with the provision

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

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

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

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

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

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

Charitable Trust 12-10-2017 6,00,000 8 Sri Ramakrishna Seva Samithi 06-03-2018 10,00,000 Sub Total 2,48,50,000 9 Sahrudaya Health, Medical & Educational Trust 30-04-2017 7,00,000 31-05-2017 8,00,000 Sub Total 15,00,000 30-04-2017 1,36,749 31-05-2017 15

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

MYADAM KISHAN RAO CHARITABLE TRUST,HYDERABAD vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Manjunatha G., Hon'Ble & Shri K.Narasimha Chary, Hon'Ble

charitable trust registered u/s. 12A of the Income Tax Act, 1961 (“the Act”) vide order dt. 15-08-1992. Subsequently, the assessee got re- registered u/s. 12A of the Act and obtained registration u/s. 12A(1)(ac) of the Act for the AY. 2022-23 to 2026-27 as per new regime of registration of trust and institutions. The main

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

15. The learned Senior Counsel for the assessee further submitted that Section 80A(5) provides that if the assessee fails to make a claim in his return of income for any deduction under Section 10A or Section 10AA or Section 10B or Section 10BA, or under any provisions of this Chapter under the heading “C- Deductions in respect of certain

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:

section 11(1) of the Act, the assessee trust was entitled to accumulate 15% of its gross income, which amounted to Rs.1,76,700/-. Accordingly, the AO observed that there was an excess 3 Ameenamma Charitable