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)

Charitable and Hindu Religious Institutions Endowment Act, 1987). The assessee temple has not filed any return of income and claimed that it is exempt u/s 10(23BBA) of the Act on the strength that the assessee temple is managed/administered by the Govt. through the authority appointed under the Endowment Act and therefore, the de facto representation of Endowment Temples including

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)

Charitable and Hindu Religious Institutions Endowment Act, 1987). The assessee temple has not filed any return of income and claimed that it is exempt u/s 10(23BBA) of the Act on the strength that the assessee temple is managed/administered by the Govt. through the authority appointed under the Endowment Act and therefore, the de facto representation of Endowment Temples including

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)

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 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

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

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

section 40A(2)(b) are not attracted to the transactions entered into between the appellant company and M/s. Ramanaidu Charitable Trust. 8.2 Regarding the reasonableness of the cost of acquisition of rights of film 'Soggadu’, the appellant following a consistent method of accounting in its transactions with M/s Ramanaidu Charitable Trust, which was accepted by the department all along

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

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 purpose or not achieved as prescribed under law. However presently the situation is that the Revenue has not said about any immoral activity of the appellant or the collection of fees was by wrongful means. Prima facie no case was made out by the Ld. PCIT (Central) so as to even vaguely demonstrate that the activities of the appellant

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

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

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

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

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 Vs. ITO [2024] 166 taxmann.com 524 (Bangalore - Trib.) wherein it has been held that there are ample decisions of this Tribunal, wherein it is observed that filing of Form 10B is not mandatory but directory, when the audit report is available while passing the intimation under section 143(1)(a) and, when the requirement of law are complied with

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