RAI SAHAB BHAIYALAL DUBEY EDUCATIONAL AND MEDICAL CHARITABLE TRUST,JABALPUR vs. INCOME TAX OFFICER (EXEMPTION), JABALPUR

In the result, the appeal is partly allowed for statistical purposes

Bench: Shri Anadee Nath Misshra

Exemption Ward Jabalpur) Charitable Trust, Jabalpur 1st Floor Prestige Alpha No.481, 48/2, 201/15, Gorakhpur Road Ratan Beratenaagrahara Begur Hosur Road

ATHITHEYAM NYAS,ANUPPUR vs. CIT (EXEMPTION) BHOPAL,, BHOPAL

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

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y.-Na Athitheyam Nyas, Vs. Commissioner Of Income-Tax C/O Kalyan Sewa Ashram, Amraknatk (Exemption), Bhopal Dt-Anuppur, M.P. 484886 Pan:Aakta1783A (Appellant) (Respondent) Assessee By: Sh. P.C. Bardia & Sh. Rahul Bardia, C.As. Revenue By: Sh. Shravan Kumar Meena, Cit Dr Date Of Hearing: 18.09.2025 Date Of Pronouncement: 30.09.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit (Exemption), Bhopal Wherein The Ld. Cit (Exemption) Has Rejected The Application Filed By The Assessee In Form No. 10Ab For Registration Under Section 12B Of The Income Tax Act. The Grounds Of Appeal Are As Under:- “1. That Without Considering The Reply E Filed/Mailed Dated 20.03.2024, The Cit(Exemp) Erred In Cancelling The Provisional Registration Granted On 28.11.2023 & Rejecting 10Ab Form For Permanent Registration Vide Order Dated 21.03.2025 Due To Non-Submission Of Reply To Notice Dated 13.03.2025 Up To 18.03.2025 Alleging: - 1. Failure To Explain The Reason For Delay In Filling Form 10Ab Without Considering Fresh/Corrected 10Ab Form Filed On 18.03.2025 U/S 12A(Ac)(1)(Vi)(B) Under New Law. 2. Not Justifying Dissolution Clause No. 23 Allowing Use Of Funds By The Settlors/Trustees- Without Referring Clause No. 19,20, 21 & 22 Of The Trust Deed. 3. The Trust Is Irrevocable- Not Correct-Without Referring Irrevocable Clause No. 19 Of The Trust Deed.

Charitable trust-order dated 28.03.2024, ITAT Delhi- ITA No. 1553/Del/2024 order dated 5.06.2024. 5. The appellant craves leave to add/alter/ amend any of the ground(s) of appeal before or at the time of hearing appeal” 3. The facts of the case are that the assessee applied in Form 10AB for registration under section 12AB. The ld. CIT (Exemption

SARIPUTTA CHARITABLE TRUST,CHHINDWARA vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BHOPAL

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

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2021-22 Sariputta Charitable Trust Commissioner Of Income V. Tax (Exemption) Khajri Dhimradhan, Chhindwara, 480001. Room No.201, Ii Floor, Reac, Bhopal, 462016, Madhya Pradesh. Pan:Aarts8965K (Appellant) (Respondent) Appellant By: Shri Sapan Usrethe, Adv Respondent By: Shri Shrawan Kumar Meena, Cit-Dr Date Of Hearing: 21 05 2025 Date Of Pronouncement: 11 06 2025 O R D E R

Charitable Trust Commissioner of Income v. Tax (Exemption) Khajri Dhimradhan, Chhindwara, 480001. Room No.201, II Floor, REAC, Bhopal, 462016, Madhya

SARIPUTTA CHARITABLE TRUST,CHHINDWARA vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BHOPAL

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

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2022-23 Sariputta Charitable Trust V. Commissioner Of Income Khajri Dhimradhan, Tax (Exemption) Chhindwara, 480001. Room No.201, Ii Floor, Reac, Bhopal, 462016, Madhya Pradesh. Pan:Aarts8965K (Appellant) (Respondent) Appellant By: Shri Sapan Usrethe, Adv Respondent By: None Date Of Hearing: 06 01 2025 Date Of Pronouncement: 07 01 2025 O R D E R

Charitable Trust v. Commissioner of Income Khajri Dhimradhan, Tax (Exemption) Chhindwara, 480001. Room No.201, II Floor, REAC, Bhopal, 462016, Madhya

SHRI NAMIYUN PARSWANATH JAIN, SWETAMBER MANIDHARI TRUST,JABALPUR vs. INCOME TAX OFFICER(EXEMPTION), JABALPUR

In the result, impugned order is set aside and appeal by assessee is allowed for statistical purposes”

charitable trust registered under section 12AA of the Act and has been purportedly enjoying the benefits of section 11 since 2011. In the impugned assessment year the benefit of exemption

KATNI BLOOD DONOR AND WELFARE SOCIETY,KATNI vs. CIT-EXCEMPTION , BHOPAL

In the result, ITA No.56/JAB/2024 is partly allowed while ITA

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

Exemption) had failed to appreciate the fact that, “within six months of commencement of its activities” had to be applied only to those trusts and institutions which had not started charitable

KATNI BLOOD DONOR AND WELFARE SOCIETY,KATNI vs. CIT- EXCEMPTION , BHOPAL

In the result, ITA No.56/JAB/2024 is partly allowed while ITA

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

Exemption) had failed to appreciate the fact that, “within six months of commencement of its activities” had to be applied only to those trusts and institutions which had not started charitable

KRISHI UPAJ MANDI SAMITI,NARSINGPUR vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE 2(1), JABALPUR

In the result, both the appeals are partly allowed for statistical purposes

Bench: Shri Anadee Nath Misshra

Charitable Trust (2001) 248 ITR 730 (Madhya Pradesh). (C) At the time of hearing, there was no representation from the assessee’s side. In the absence of any representation from the assessee’s side, the learned Departmental Representative (“DR”, for short) for Revenue was heard. The aforesaid paper book, referred to in paragraph (B.1) of this order, contains a brief

KRISHI UPAJ MANDI SAMITI ,NARSINGPUR vs. ASST. COMMISSIONER OF INCOMETAX, CIRCLE 2(1), JABALPUR

In the result, both the appeals are partly allowed for statistical purposes

Bench: Shri Anadee Nath Misshra

Charitable Trust (2001) 248 ITR 730 (Madhya Pradesh). (C) At the time of hearing, there was no representation from the assessee’s side. In the absence of any representation from the assessee’s side, the learned Departmental Representative (“DR”, for short) for Revenue was heard. The aforesaid paper book, referred to in paragraph (B.1) of this order, contains a brief

MANGALAYATAN UNIVERSITY,JABALPUR vs. COMMISSIONER OF INCOME TAX, EXCEMPTION, BHOPAL

In the result, ITA No. 46/JAB/2025 is allowed for statistical purposes while

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

trust to M/s Helpage Finlease Limited, New Delhi have not been clearly brought on record. Ongoing through the agreement dated 16.03.2022, it is seen that the loan was to be disbursed within one month of providing of all documents. The date of actual disbursal of this loan does not figure in the order of the ld. CIT(Exemption) and therefore

MANGALAYATAN UNIVERSITY,MANDLA ROAD, NEAR SHARDA DEVI MANDIR, RICHAI BAREL vs. LD. CIT (EXEMPTION), BHOPAL, MADHYA PRADESH

In the result, ITA No. 46/JAB/2025 is allowed for statistical purposes while

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

trust to M/s Helpage Finlease Limited, New Delhi have not been clearly brought on record. Ongoing through the agreement dated 16.03.2022, it is seen that the loan was to be disbursed within one month of providing of all documents. The date of actual disbursal of this loan does not figure in the order of the ld. CIT(Exemption) and therefore

ACHARIYA SHREE VIDHYA SAGAR DAYODAY PASHU SEVA KENDRA TENDUKHEDA DAMOH,VIDHYA NAGAR TENDUKHEDA DAMOH vs. COMMISSIONER (EXEMPTION), BHOPAL

In the result, both the appeals in ITA Nos

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

charitable activities and the ld. AO has recorded the same in his assessment order. We also observed that the ld. CIT (Exemption) on account of the fact that the application was getting barred by limitation and the failure of the assessee trust

ACHARYA SHREE VIDHYASAGAR DAYODAY PASHU SEWA KENDRA TENDUKHEDA DAMOH,TENDUKHEDA DAMOH vs. COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL

In the result, both the appeals in ITA Nos

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

charitable activities and the ld. AO has recorded the same in his assessment order. We also observed that the ld. CIT (Exemption) on account of the fact that the application was getting barred by limitation and the failure of the assessee trust

SRI GURUTEGH BAHADUR EDUCATION SOCIETY ,JABALPUR vs. COMMISSIONER OF INCOME TAX, EXEMPTION, , BHOPAL

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

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadalesri Gurutegh Bahadur Vs Cit (Exemption), Education Society, 1, Sri Bhopal. Gurutegh Bahadur Khalasa College, Mahanadda, Nagpur Road, Jabalpur, Madhya Pradesh-482002. (Appellant) (Respondent) Pan No.Aaeas6226R Assessee By Shri H.S.Modh, Adv. Revenue By Shri Shiv Kumar, Sr.Dr Date Of Hearing 18/09/2023 Date Of Pronouncement 22/09/2023

exemption from taxation will be available only after the Assessing Officer is satisfied about the genuineness of the activities promised or claimed to be carried on in each Financial Year relevant to the Assessment Year and all the provisions of law acted upon. This will be further subject to provisions of section 2(15) of the Income

SHREE AGRAWAL MANDAL,CHHINDWARA vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BHOPAL

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Shri Kul Bharat & Shri, Anadee Nath Misshra

Exemption) was grossly erred in rejecting the application filed for approval u/s. 80G(5) and also in cancelling the provisional approval granted. 3. The above grounds of appeal are without prejudice and notwithstanding each other. Any consequential relief, to which the appellant may be entitled under the law in pursuance of the aforesaid grounds of appeal, or otherwise, may thus

SHREE AGRAWAL MANDAL,CHHINDWARA vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BHOPAL

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Shri Kul Bharat & Shri, Anadee Nath Misshra

Exemption) was grossly erred in rejecting the application filed for approval u/s. 80G(5) and also in cancelling the provisional approval granted. 3. The above grounds of appeal are without prejudice and notwithstanding each other. Any consequential relief, to which the appellant may be entitled under the law in pursuance of the aforesaid grounds of appeal, or otherwise, may thus

INDIAN RED CROSS SOCIETY DISTRICT OFFICE SINGRAULI,SINGRAULI vs. CIT EXEMPTION, BHOPAL

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

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadaleita No. 29 & 96/Jab/2023 (A.Y: 2023-24) Indian Red Cross Society Vs. Cit (Exemption), (District Office Bhopal-462016, Singrauli) Ntpc Madhya Pradesh. Hospital, Vidhyanagar, Singrauli-486885. Madhya Pradesh. Pan/Gir No. : Aabai0508B Appellant .. Respondent Assessee By : Shri.Majon Jain. Fca .Ar Revenue By : Shri.Rajesh Kumar Gupta. Sr. Dr Date Of Hearing 21.09.2023 Date Of Pronouncement 09.10.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: These Two Appeals Are Filed By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Exemption)(Cit(E)) Bhopal Denying The Registration U/Sec 12Aa & Approval U/Sec 80G Of The Act.

EXEMPTION declining registration u/s 12AA is only on the basis of change of opinion and contrary to the facts, law and principles of natural justice. 3. The order is contested in appeal on every cogent grounds and the appellant craves for the indulgence of the Hon'ble ITAT, to allow it (the appellant) to take such additional grounds and/or