ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 2(15) of the Act. 17. Powers and functions of the Respondent: - The Uttar Pradesh Avas Evam Vikas Parishad Adhiniyam, i. 1965 (“Regulation”), brought into existence the Respondent. Clause 15 of the Regulation defines the functions of this board, and the primary functions are to frame and execute housing schemes, to plan and coordinate various housing activities, to manage

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 2(15) of the Act. 17. Powers and functions of the Respondent: - The Uttar Pradesh Avas Evam Vikas Parishad Adhiniyam, i. 1965 (“Regulation”), brought into existence the Respondent. Clause 15 of the Regulation defines the functions of this board, and the primary functions are to frame and execute housing schemes, to plan and coordinate various housing activities, to manage

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 2(15) of the Act. 17. Powers and functions of the Respondent: - The Uttar Pradesh Avas Evam Vikas Parishad Adhiniyam, i. 1965 (“Regulation”), brought into existence the Respondent. Clause 15 of the Regulation defines the functions of this board, and the primary functions are to frame and execute housing schemes, to plan and coordinate various housing activities, to manage

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 2(15) of the Act. 17. Powers and functions of the Respondent: - The Uttar Pradesh Avas Evam Vikas Parishad Adhiniyam, i. 1965 (“Regulation”), brought into existence the Respondent. Clause 15 of the Regulation defines the functions of this board, and the primary functions are to frame and execute housing schemes, to plan and coordinate various housing activities, to manage

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 2(15) of the Act. 17. Powers and functions of the Respondent: - The Uttar Pradesh Avas Evam Vikas Parishad Adhiniyam, i. 1965 (“Regulation”), brought into existence the Respondent. Clause 15 of the Regulation defines the functions of this board, and the primary functions are to frame and execute housing schemes, to plan and coordinate various housing activities, to manage

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 2(15) of the Act. 17. Powers and functions of the Respondent: - The Uttar Pradesh Avas Evam Vikas Parishad Adhiniyam, i. 1965 (“Regulation”), brought into existence the Respondent. Clause 15 of the Regulation defines the functions of this board, and the primary functions are to frame and execute housing schemes, to plan and coordinate various housing activities, to manage

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 2(15) of the Act. 17. Powers and functions of the Respondent: - The Uttar Pradesh Avas Evam Vikas Parishad Adhiniyam, i. 1965 (“Regulation”), brought into existence the Respondent. Clause 15 of the Regulation defines the functions of this board, and the primary functions are to frame and execute housing schemes, to plan and coordinate various housing activities, to manage

ROHILKHAND EDUCATIONAL CHARITABLE TRUST,BAREILLY vs. DCIT, CENTRAL CIRCLE, BAREILLY

In the result, both appeals of the assessee in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.181 & 182/Lkw/2024 A.Ys.2017-18 & 2018-19 Rohilkhand Educational Vs. Dcit, Charitable Trust, Bareilly Central Circle, Bareilly Pan: Aaatr6902J (Appellant) (Respondent) Assesseeby: Sh. Rakesh Garg, Adv Revenue By: Sh. S.H. Usmani, Cit Dr Date Of Hearing: 14.08.2025 Date Of Pronouncement: 22.09.2025 O R D E R Per Bench: [ These Two Appeals Have Been Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A)-3, Lucknow Dated 19.03.2024 & 22.03.2024, Passed Under Section 250 Of The Income Tax Act, 1961, For The A.Ys. 2017-18 & 2018-19, Dismissing The Appeals Of The Assessee Against Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “(1).That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Not Considering The Fact That In The Alleged Assessment Order, The Columns Of Name Of Assessee, Pan, Asst Year, Date Of Assessment & Section Under Which Passed, Are Blank. (2)That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Treating The Demand As Valid Which Was Not Computed On The Basis Of Orderthat May Not Be Termed To Be An Order Under Section 143(3). (3) That A Demand Of Tax As Computed In The Computation Sheet Is Without Jurisdiction Void-Ab-Inito & Is Liable To Be Annulled. (4) That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Confirming The Addition Of Rs. 736591857/-Comprising  Corpus Donation Aggregating To Rs 7,68,95,000/-, A.Ys. 2017-18 & 2018-19

iii) That the above exemption has been denied invoking the provisions of section 13(3) of the Act, without giving any specific findings in this regard. A.Ys. 2017-18 & 2018-19 8. The learned authorities below have erred in law as well as on facts in not allowing the charitable expenditure at Rs. 20 crore, being donation to other charitable

ROHILKHAND EDUCATIONAL CHARITABLE TRUST,BAREILLY vs. DCIT, CENTRAL CIRCLE, BAREILLY

In the result, both appeals of the assessee in ITA No

iii) That the above exemption has been denied invoking the provisions of section\n13(3) of the Act, without giving any specific findings in this regard.\n8. The learned authorities below have erred in law as well as on facts in not allowing\nthe charitable expenditure at Rs.20 crore, being donation to other charitable trust\nregistered under section

LUCKNOW DEVELOPMENT AUTHORITY,LUCKNOW vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, all the appeals are partly allowed

Bench: Shri A. D. Jain & Shri T. S. Kapoor

17 and 18 of UPUPD Act provides the procedure and power for acquisition and disposal of land acquired for development. 9. Sub-section (2) of Section 20 of UPUPD Act debars the Authority to apply the funds for any purpose other than meeting the expenses in administration of UPUPD Act. 10. Section 41 of UPUPD Act deals with control

LUCKNOW EVELOPMENT AUTHORITY,LUCKNOW vs. I.T.O., LUCKNOW

In the result, all the appeals are partly allowed

Bench: Shri A. D. Jain & Shri T. S. Kapoor

17 and 18 of UPUPD Act provides the procedure and power for acquisition and disposal of land acquired for development. 9. Sub-section (2) of Section 20 of UPUPD Act debars the Authority to apply the funds for any purpose other than meeting the expenses in administration of UPUPD Act. 10. Section 41 of UPUPD Act deals with control

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. ACIT (E), LUCKNOW

In the result, all the appeals are partly allowed

Bench: Shri A. D. Jain & Shri T. S. Kapoor

17 and 18 of UPUPD Act provides the procedure and power for acquisition and disposal of land acquired for development. 9. Sub-section (2) of Section 20 of UPUPD Act debars the Authority to apply the funds for any purpose other than meeting the expenses in administration of UPUPD Act. 10. Section 41 of UPUPD Act deals with control

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. ACIT (E), LUCKNOW

In the result, all the appeals are partly allowed

Bench: Shri A. D. Jain & Shri T. S. Kapoor

17 and 18 of UPUPD Act provides the procedure and power for acquisition and disposal of land acquired for development. 9. Sub-section (2) of Section 20 of UPUPD Act debars the Authority to apply the funds for any purpose other than meeting the expenses in administration of UPUPD Act. 10. Section 41 of UPUPD Act deals with control

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. DCIT (E), LUCKNOW

In the result, all the appeals are partly allowed

Bench: Shri A. D. Jain & Shri T. S. Kapoor

17 and 18 of UPUPD Act provides the procedure and power for acquisition and disposal of land acquired for development. 9. Sub-section (2) of Section 20 of UPUPD Act debars the Authority to apply the funds for any purpose other than meeting the expenses in administration of UPUPD Act. 10. Section 41 of UPUPD Act deals with control

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

Bench: Shri A. D. Jain & Shri T. S. Kapoor

property or contribute towards the cost of any such investigation, examination or survey made by any local authority or the state Government. n) To levy betterment fees. o) To fulfil any other obligation imposed by or under this Act or any other law for the time being in force, and p) To do all such other acts and things

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

Bench: Shri A. D. Jain & Shri T. S. Kapoor

property or contribute towards the cost of any such investigation, examination or survey made by any local authority or the state Government. n) To levy betterment fees. o) To fulfil any other obligation imposed by or under this Act or any other law for the time being in force, and p) To do all such other acts and things

M/S U.P AWAS EVAM VIKAS PARISHAD,LUCKNOW vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

Bench: Shri A. D. Jain & Shri T. S. Kapoor

property or contribute towards the cost of any such investigation, examination or survey made by any local authority or the state Government. n) To levy betterment fees. o) To fulfil any other obligation imposed by or under this Act or any other law for the time being in force, and p) To do all such other acts and things

RAEBARELI DEVELOPMENT AUTHORITY,RAEBARELI vs. CIT-A, NFAC DELHI

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

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

properties, movable and immovable; and (e) All moneys received by the Authority by way of rents and profits or in any other manner or From any other source. (f) The fund shall be applied towards meeting the expenses incurred by the Authority 1n the Administration of this Act and for no other purposes. 3. (8). All these provisions