SHRI SANJAY GARG (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

The Tribunal followed the decisions of the ITAT and the Rajasthan High Court, which held that the assessee qualified for exemption under Section 10(23C)(iiiab) as an educational institution. The court's prior ruling established the assessee as an educational institution existing solely for education.

SHRI SANJAY GARG (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

The Tribunal held that the issue is squarely covered by the decision of the Hon'ble ITAT in the assessee's own case, which followed the order of the Hon'ble Rajasthan High Court. Since there was no change in facts for the assessment years in question, the Tribunal respectfully followed the ITAT's decision and allowed the claim for exemption under Section 10(23C)(iiiab) of the Act.

SHRI SANJAY GARG (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

The Tribunal noted that the issue was covered by previous decisions of the ITAT and the Rajasthan High Court. Since there were no changes in facts across the assessment years, the Tribunal followed the precedents and allowed the claim for exemption under Section 10(23C)(iiiab).

SHRI SANJAY GARG (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

The Tribunal followed the decisions of the Hon'ble ITAT and the Hon'ble Rajasthan High Court in the assessee's own case, which allowed the claim for exemption under Section 10(23C)(iiiab). The Tribunal found that the facts were not changed from the previous assessment years and respectfully followed the precedent.

SHRI SANJAY GARG (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

The Tribunal held that the issue is covered by the decisions of the Hon'ble ITAT and the Rajasthan High Court in the assessee's own case. Following these precedents, the Tribunal allowed the claim of exemption under Section 10(23C)(iiiab) of the Act, finding no change in facts across the assessment years.

SHRI SANJAY GARG (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

The Tribunal noted that similar issues in earlier assessment years were decided in favour of the assessee by the ITAT, following the Rajasthan High Court's decision. Given no change in facts across the assessment years, the Tribunal respectfully followed the previous ITAT ruling and allowed the claim for exemption under Section 10(23C)(iiiab).

SHRI SANJAY GARG (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

The Tribunal noted that the issue was covered by previous ITAT decisions which relied on the Rajasthan High Court's ruling. Since there was no change in facts, the Tribunal followed the ITAT's order and allowed the exemption. Other additions made by the AO became infructuous.

SHRI SANJAY GARG (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

The Tribunal held that the assessee's activities qualified for exemption under Section 10(23C)(iiiab) of the Income Tax Act. The decision relied on prior rulings of the ITAT and the Rajasthan High Court, which had held the assessee to be an educational institution existing solely for education. The Tribunal found no change in facts across the assessment years considered.

SHRI SANJAY GARG (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

The Tribunal held that the issue is squarely covered by the decision of the Hon'ble ITAT, which followed the order of the Hon'ble Rajasthan High Court. Since there was no change in facts across the assessment years, the Tribunal respectfully followed the decision of the Hon'ble ITAT and allowed the claim for exemption.

SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

The Tribunal held that the penalty appeal cannot be adjudicated as the quantum issues are yet to be determined by the CIT (Appeals). The Tribunal set aside the order of the CIT (Appeals) and relegated the issue to the CIT (Appeals) for fresh adjudication after the quantum appeal is decided.

SMT. ANNAPURNA GUPTA (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

The Tribunal held that the assessee had provided sufficient documentary evidence to prove the genuineness of the loan transaction, including confirmations and bank statements, and had also demonstrated the return of the loan within the same financial year. The Tribunal found no basis for treating the loan as an accommodation entry, as the revenue's case was based on general statements and assumptions rather than concrete evidence.

SMT. ANNAPURNA GUPTA (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

The Tribunal observed that the assessee failed to produce evidence such as lease agreements or revenue records to substantiate its claim that the land was used for agricultural purposes. Despite repeated opportunities, the necessary documents were not furnished.

SMT. ANNAPURNA GUPTA (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

The tribunal observed that the applicant had not fully complied with the directions of the CIT(E) and had failed to furnish necessary replies and documents. However, considering the subsequent registration under the RPT Act and the request for another opportunity, the tribunal deemed it fit to restore the application.

SMT. ANNAPURNA GUPTA (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

The Tribunal observed that the appellant society repeatedly failed to furnish required documents and information despite ample opportunities and notices from the learned CIT(E). While the grounds of appeal regarding limitation were not pressed, the Tribunal found it fit to allow the restoration of the matters to the learned CIT(E) for a fresh decision.

SMT. ANNAPURNA GUPTA (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

The Tribunal noted that the appellant society failed to provide the requisite details and clarifications despite multiple opportunities. The CIT(E) was justified in concluding that the genuineness of the activities could not be ascertained. However, considering the peculiar facts, the Tribunal allowed the restoration of the matters to the CIT(E) for a fresh decision.