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)

Trust established wholly for religious and charitable purpose and therefore, as per sub-section (2) of Section 115BBC, the provisions of sub-section (1) shall not apply to the anonymous donation received by the assessee. However, this section provides only the rate of tax applicable on the anonymous donation received by the assessee and in case the said anonymous donation

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)

section 12AA(3) needs to be satisfied are: (a) That activities of the trust/institution are not genuine. (b) That activities of the trust are not carried out in accordance with the objects of the trust/institution. Thus the findings of the CIT has not to be only conceptual or contextual but should be within the four corners of law so that

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)

section 12AA(3) needs to be satisfied are: (a) That activities of the trust/institution are not genuine. (b) That activities of the trust are not carried out in accordance with the objects of the trust/institution. Thus the findings of the CIT has not to be only conceptual or contextual but should be within the four corners of law so that

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

SECUNDERABAD TWIN AREA ROUND TABLE CHARITABLE TRUST,HYDERABAD vs. CIT (EXEMPTION), HYDERABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

section 12AB of the Act on the ground that the charitable activities were not substantiated with verifiable documentary evidence. 4. Aggrieved with the order of Ld. CIT(E), the assessee is in appeal before the Tribunal. The Learned Authorised Representative (“Ld. AR”) submitted that the assessee had filed all the required information and documents called

KRANTHI EDUCATIONAL SOCIETY,BHADRACHALLAM vs. DCIT., EXEMPTION CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes in terms of our observations given hereinabove

Bench: the Ld. CIT(A).

Charitable Institution which claims benefit for Sections 11 and 12 of the Act. Therefore, on this ground, the denial of exemption by the A.O. is incorrect. Similarly, in respect of the arguments of the learned counsel for the assessee in light of provisions of Section 143(1)(a) of the Act, that denial of exemptions cannot be considered

DEVGEM SEEDS AND CROP TECHNOLOGY PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-17(1), HYDERABAD

Appeals are dismissed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahuappellant Respondent

57,890/- and Rs.1,09,31,000/-; respectively regarding interest paid to overseas Associated Enterprises (AEs) of Fully Convertible Debentures (FCDs). 3. The Revenue next sought to highlight the fact of the learned lower authorities; right from the Transfer Pricing Officer’s (TPOs) to the DRP, have adopted judicial consistency in light of the very issue finalized in preceding AY.2011-12

DEVGEN SEEDS AND CROP TECHNOLOGY PRIVATE LIMITED, SECUNDERABAD,HYDERABAD vs. ACIT,CIRCLE-17(1) HYDERABAD, HYDERABAD

Appeals are dismissed in above terms

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahuappellant Respondent

57,890/- and Rs.1,09,31,000/-; respectively regarding interest paid to overseas Associated Enterprises (AEs) of Fully Convertible Debentures (FCDs). 3. The Revenue next sought to highlight the fact of the learned lower authorities; right from the Transfer Pricing Officer’s (TPOs) to the DRP, have adopted judicial consistency in light of the very issue finalized in preceding AY.2011-12

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(4), HYDERABAD vs. RAVI RISHI EDUCATIONAL SOCIETY, HYDERABAD

In the result, the appeal of the revenue in ITA

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

charitable purposes as mandated by Section 11 of the Income Tax Act and hence the exemption granted to it u/s 11 is being denied. Thus, the income of the assessee as per its income and expenditure statement amounting to Rs.9,03,81,292/- is being added to its returned income. [Addition: Rs. 9,03,81,292/-] Penalty provisions

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(4), HYDERABAD vs. RAVI RISHI EDUCATIONAL SOCIETY, HYDERABAD

In the result, the appeal of the revenue in ITA

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

charitable purposes as mandated by Section 11 of the Income Tax Act and hence the exemption granted to it u/s 11 is being denied. Thus, the income of the assessee as per its income and expenditure statement amounting to Rs.9,03,81,292/- is being added to its returned income. [Addition: Rs. 9,03,81,292/-] Penalty provisions

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(4), HYDERABAD vs. RAVI RISHI EDUCATIONAL SOCIETY, HYDERABAD

In the result, the appeal of the revenue in ITA

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

charitable purposes as mandated by Section 11 of the Income Tax Act and hence the exemption granted to it u/s 11 is being denied. Thus, the income of the assessee as per its income and expenditure statement amounting to Rs.9,03,81,292/- is being added to its returned income. [Addition: Rs. 9,03,81,292/-] Penalty provisions

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(4), HYDERABAD vs. RAVI RISHI EDUCATIONAL SOCIETY, HYDERABAD

In the result, the appeal of the revenue in ITA

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

charitable purposes as mandated by Section 11 of the Income Tax Act and hence the exemption granted to it u/s 11 is being denied. Thus, the income of the assessee as per its income and expenditure statement amounting to Rs.9,03,81,292/- is being added to its returned income. [Addition: Rs. 9,03,81,292/-] Penalty provisions

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(4), HYDERABAD vs. RAVI RISHI EDUCATIONAL SOCIETY, HYDERABAD

In the result, the appeal of the revenue in ITA

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

charitable purposes as mandated by Section 11 of the Income Tax Act and hence the exemption granted to it u/s 11 is being denied. Thus, the income of the assessee as per its income and expenditure statement amounting to Rs.9,03,81,292/- is being added to its returned income. [Addition: Rs. 9,03,81,292/-] Penalty provisions

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(4), HYDERABAD vs. RAVI RISHI EDUCATIONAL SOCIETY, HYDERABAD

In the result, the appeal of the revenue in ITA

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

charitable purposes as mandated by Section 11 of the Income Tax Act and hence the exemption granted to it u/s 11 is being denied. Thus, the income of the assessee as per its income and expenditure statement amounting to Rs.9,03,81,292/- is being added to its returned income. [Addition: Rs. 9,03,81,292/-] Penalty provisions

ASSISTANT COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE-2(4), HYDERABAD vs. RAVI RISHI EDUCATIONAL SOCIETY, HYDERABAD

In the result, the appeal of the revenue in ITA

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

charitable purposes as mandated by Section 11 of the Income Tax Act and hence the exemption granted to it u/s 11 is being denied. Thus, the income of the assessee as per its income and expenditure statement amounting to Rs.9,03,81,292/- is being added to its returned income. [Addition: Rs. 9,03,81,292/-] Penalty provisions

SAGARA KSHATRIYA WELFARE AND CHARITABLE TRUST ,HYDERABAD vs. INCOME TAX OFFICER, EXEMPTION WARD 1(4), HYD, HYDERABAD

In the result, appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

Charitable Trust (“the assessee”) for the assessment year 2022-23, assessee preferred this appeal. 2. Brief facts of the case are that the assessee is a Registered Society having registration under section 12A of the Income Tax Act, 1961 (for short “the Act”). It is said to have been running for welfare of the poor and needy and Kshatriya community

ACIT, CENTRAL CIRCLE-3(1), HYDERABAD vs. VAMSI MOHAN VALLABHANENI, VIJAYAWADA

In the result, the appeal of Revenue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2010-11 Deputy Commissioner Of Income Vs. Sri Vamsi Mohan Vallabhaneni, Tax, R/O.Vijayawada. Central Circle – 3(1), Hyderabad. Pan : Adrpv4231C (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao, C.A. Revenue By: Ms. M. Narmadha, Cit-Dr Date Of Hearing: 10.12.2024 10.12.2024 Date Of Pronouncement:

57,496/- towards unexplained advances from customers. Finally, the Assessing Officer passed assessment order u/s 143(3) of the Act on 28.12.2011, assessing the total income of the assessee at Rs.20,98,14,841/-. 4. Feeling aggrieved with the order of Assessing Officer, assessee filed appeal before the LD.CIT(A), who granted relief to the assessee by deleting the addition

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

Charitable Trust [2011] 13 taxmann.com 50 (Hyderabad), wherein it was held that "it was not open to Tribunal to entertain second application which was filed on same set of facts and to recall its appellate order on alleged premise that there was an error apparent in order of Tribunal". Madhucon Projects Limited, Hyderabad. 4. Reliance is also placed

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

Charitable Trust [2011] 13 taxmann.com 50 (Hyderabad), wherein it was held that "it was not open to Tribunal to entertain second application which was filed on same set of facts and to recall its appellate order on alleged premise that there was an error apparent in order of Tribunal". Madhucon Projects Limited, Hyderabad. 4. Reliance is also placed