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

charitable\ntrust u/s 80G(2)(iv) read with section 80G(1)(ii) of the Act.\n23.\nAs discussed supra, we concur with the contention of the\nassessee that since Parliament intended certain restrictions to\nonly CSR expenditure in respect of two donations included by\nan assessee as CSR expenditure i.e. [Swachh Bharat Kosh and\nClean Ganga Fund] has impliedly

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

Charitable Trust and Sewa International, which are eligible for 50% Page 2 of 13 ITA-TP Nos. 145 & 482/Hyd/2022 deduction u/s 80G of the Act. Accordingly, assessee claimed deduction of Rs. 1,33,27,000/-. 5. Learned Assessing Officer, however, disallowed the deduction under section 80G of the Act stating that CSR expenditure incurred u/s 135 of Companies

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

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

Charitable Trust and Sewa International, which are eligible for 50% Page 2 of 13 ITA-TP Nos. 145 & 482/Hyd/2022 deduction u/s 80G of the Act. Accordingly, assessee claimed deduction of Rs. 1,33,27,000/-. 5. Learned Assessing Officer, however, disallowed the deduction under section 80G of the Act stating that CSR expenditure incurred u/s 135 of Companies

DELOITTEE TAX SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals are allowed

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

charitable trust u/s 80G(2)(iv) read with Section 80G(1)(ii) of the Act. 23. As discussed supra, we concur with the contention of the assessee that since Parliament intended certain restrictions to only CSR expenditure in respect of two donations included by an assessee as CSR expenditure i.e. [Swachh Bharat Kosh and Clean Ganga Fund] has impliedly

DELOITTE & TOUCHE ASSURANCE & ENTERPRISE RISK SERVICES INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-8(1), HYDERABAD

In the result, both the appeals are allowed

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdia

charitable trust u/s 80G(2)(iv) read with Section 80G(1)(ii) of the Act. 23. As discussed supra, we concur with the contention of the assessee that since Parliament intended certain restrictions to only CSR expenditure in respect of two donations included by an assessee as CSR expenditure i.e. [Swachh Bharat Kosh and Clean Ganga Fund] has impliedly

POWER MECH PROJECTS LIMITED,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(3), HYDERABAD

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

trust as business expenditure and in compliance with the proviso to section 37(1) of the Act, the assessee suomoto disallowed the same, but since there is no bar in the Act, from claiming this expenditure as deduction under section 80G of the same, such a claim cannot be denied. 5. Learned AR further argued that there

AASHRITHA THE DR U SANKARANARAYANA RAJU CHARITABLE TRUST,HYDERABAD vs. CIT (EXEMPTIONS), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos. 208 & 209/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23 & 2025-26) Aashritha The Dr U Vs. Cit (Exemptions) Sankaranarayana Raju Hyderabad Charitable Trust, Hyderabad Pan:Aacta3113G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.S.Rajendra Kumar, Irs (Retired) राज" व "ारा/Revenue By:: Shri Narender Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/07/2025 घोषणा की तारीख/Pronouncement: 16/07/2025 आदेश/Order Per Vijay Pal Rao

section code instead of renewal of the resignation u/s 12AB and approval u/s 80G(5), a provisional registration and approval was Page 5 of 13 ITA Nos 208 and 209 of 2025 Ashritha The Dr U Sankaranarayana Raju Charitable Trust granted. Thus, the learned AR has submitted that the application filed by the assessee ought to have been considered

AASHRITHA THE DR U SANKARANARAYANA RAJU CHARITABLE TRUST,HYDERABAD vs. CIT (EXEMPTIONS), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos. 208 & 209/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2022-23 & 2025-26) Aashritha The Dr U Vs. Cit (Exemptions) Sankaranarayana Raju Hyderabad Charitable Trust, Hyderabad Pan:Aacta3113G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.S.Rajendra Kumar, Irs (Retired) राज" व "ारा/Revenue By:: Shri Narender Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/07/2025 घोषणा की तारीख/Pronouncement: 16/07/2025 आदेश/Order Per Vijay Pal Rao

section code instead of renewal of the resignation u/s 12AB and approval u/s 80G(5), a provisional registration and approval was Page 5 of 13 ITA Nos 208 and 209 of 2025 Ashritha The Dr U Sankaranarayana Raju Charitable Trust granted. Thus, the learned AR has submitted that the application filed by the assessee ought to have been considered

SEVAGRAMAM CHARITABLE TRUST,HYDERABAD vs. CIT (EXEMPTION), HYDERABAD

Bench: Us:

5. In response, the CIT (Exemptions) initiated proceedings under Section 12A(1)(ac)(vi)(B) of the Act and issued notices dated 03.12.2024 and 07.02.2025, to which the assessee trust responded with complete documentation and clarifications. However, the CIT (Exemptions), vide his impugned order dated 12-03-2025, rejected the application for the reason that the same was filed beyond

SEVAGRAMAM CHARITABLE TRUST,HYDERABAD vs. CIT (EXEMPTION), HYDERABAD

Bench: Us:

5. In response, the CIT (Exemptions) initiated proceedings under Section 12A(1)(ac)(vi)(B) of the Act and issued notices dated 03.12.2024 and 07.02.2025, to which the assessee trust responded with complete documentation and clarifications. However, the CIT (Exemptions), vide his impugned order dated 12-03-2025, rejected the application for the reason that the same was filed beyond

MAHINDRA UNIVERSITY,HYDERABAD vs. CIT(EXEMPTION), HYDERABAD

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

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.38/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2025-26) Mahindra University Vs. Commissioner Of Income Hyderabad Tax (Exemption) Pan:Aaajm2795G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri C.S. Subrahmanyam, Ca & Advocate V Siva Kumar राज" व "ारा/Revenue By:: Smt. M Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 01/04/2025 घोषणा की तारीख/Pronouncement: 09/06/2025 आदेश/Order

vi) being solely existed for the charitable activities of imparting education as a University, then the nature of the activities of the assessee being charitable in nature cannot be disputed while granting approval u/s 80G(5) of the I.T. Act, 1961 until and unless it is found that the assessee has carried out the activities in contrary to the objects

SRI KURUMURTHY SWAMY DEVASTHANAM,MAHABUBNAGAR vs. CIT (EXEMPTION), HYDERABAD.

In the result, appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.S.No Ita No Appellant Respondent 1 1043/Hyd/2025 Sri Kurumurthy Swamy Cit (Exemptions) Devasthanam, Hyderabad Mahbubnagar Pan: Aahts2887G 2 1044/Hyd/2025 -Do- -Do- 3 1049/Hyd/2025 Sri Maisamma Devatna -Do- Ammavari Devasthanam Mahbubnagar Pan:Aamts0357A 4 1050/Hyd/2025 -Do- -Do-

vi). Thus, only due to the mistake in sub clause of section 12A(1)(ac), the learned CIT (Exemption) has rejected all these applications which is highly technical. It is pertinent to note that this is only an inadvertent mistake in selecting the section code while filing the application for registration u/s 12AB as well as approval u/s 80G(5

SRI MAISAMMA DEVATNA AMMAVARI DEVASTHANAM,MAHABUBNAGAR vs. CIT(EXEMPTION), HYDERABAD

In the result, appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.S.No Ita No Appellant Respondent 1 1043/Hyd/2025 Sri Kurumurthy Swamy Cit (Exemptions) Devasthanam, Hyderabad Mahbubnagar Pan: Aahts2887G 2 1044/Hyd/2025 -Do- -Do- 3 1049/Hyd/2025 Sri Maisamma Devatna -Do- Ammavari Devasthanam Mahbubnagar Pan:Aamts0357A 4 1050/Hyd/2025 -Do- -Do-

vi). Thus, only due to the mistake in sub clause of section 12A(1)(ac), the learned CIT (Exemption) has rejected all these applications which is highly technical. It is pertinent to note that this is only an inadvertent mistake in selecting the section code while filing the application for registration u/s 12AB as well as approval u/s 80G(5

SRI MAISAMMA DEVATNA AMMAVARI DEVASTHANAM,MAHABUBNAGAR vs. CIT (EXEMPTION), HYDERABAD.

In the result, appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.S.No Ita No Appellant Respondent 1 1043/Hyd/2025 Sri Kurumurthy Swamy Cit (Exemptions) Devasthanam, Hyderabad Mahbubnagar Pan: Aahts2887G 2 1044/Hyd/2025 -Do- -Do- 3 1049/Hyd/2025 Sri Maisamma Devatna -Do- Ammavari Devasthanam Mahbubnagar Pan:Aamts0357A 4 1050/Hyd/2025 -Do- -Do-

vi). Thus, only due to the mistake in sub clause of section 12A(1)(ac), the learned CIT (Exemption) has rejected all these applications which is highly technical. It is pertinent to note that this is only an inadvertent mistake in selecting the section code while filing the application for registration u/s 12AB as well as approval u/s 80G(5

SRI KURUMURTHY SWAMY DEVASTHANAM,MAHABUBNAGAR vs. CIT(EXEMPTION), HYDERABAD

In the result, appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.S.No Ita No Appellant Respondent 1 1043/Hyd/2025 Sri Kurumurthy Swamy Cit (Exemptions) Devasthanam, Hyderabad Mahbubnagar Pan: Aahts2887G 2 1044/Hyd/2025 -Do- -Do- 3 1049/Hyd/2025 Sri Maisamma Devatna -Do- Ammavari Devasthanam Mahbubnagar Pan:Aamts0357A 4 1050/Hyd/2025 -Do- -Do-

vi). Thus, only due to the mistake in sub clause of section 12A(1)(ac), the learned CIT (Exemption) has rejected all these applications which is highly technical. It is pertinent to note that this is only an inadvertent mistake in selecting the section code while filing the application for registration u/s 12AB as well as approval u/s 80G(5

KURNOOL MEDICAL COLLEGE GRADUATE TRUST,HYDERABAD vs. CIT (EXEMPTION), HYDERABAD

Bench: Us:

vi)(A) of the Act vide order dated 3 Kurnool Medical College Vs. CIT (Exemption 31.12.2021 for the period from AY 2022-23 to AY 2024-25, Pages 41-43 of the Assessee’s Paper Book (for short, “APB”). 4. Further, the assessee trust was also granted provisional approval under section 80G(5)(iv) for the period from

FERNANDEZ FOUNDATION ,HYDERABAD vs. COMMISSIONER OF INCOME TAX (EXEMPTION) , HYDERABAD

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

section 12AA(1)(b)(ii), 80G(5)(vi) and 10(23C)(vi) of Income Tax Act, 1961 (in short, “the Act”), respectively. 2. The grounds raised by the assessee in ITA No.1884/Hyd/2019 read as under : “1. The order of the Commissioner of Income Tax (Exemptions) is contrary to the provision of law and is bad in law. 2. The order

FERNANDEZ FOUNDATION ,HYDERABAD vs. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD

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

section 12AA(1)(b)(ii), 80G(5)(vi) and 10(23C)(vi) of Income Tax Act, 1961 (in short, “the Act”), respectively. 2. The grounds raised by the assessee in ITA No.1884/Hyd/2019 read as under : “1. The order of the Commissioner of Income Tax (Exemptions) is contrary to the provision of law and is bad in law. 2. The order

FERNANDEZ FOUNDATION,HYDERABAD vs. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD

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

section 12AA(1)(b)(ii), 80G(5)(vi) and 10(23C)(vi) of Income Tax Act, 1961 (in short, “the Act”), respectively. 2. The grounds raised by the assessee in ITA No.1884/Hyd/2019 read as under : “1. The order of the Commissioner of Income Tax (Exemptions) is contrary to the provision of law and is bad in law. 2. The order