DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-1(1), MUMBAI, MUMBAI vs. ALL INDIA GEM AND JEWELLERY DOMESTIC COUNCIL, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16

trust are related parties in terms of section 13(3) of the Act and the assessee is hit by in terms of section 13(3) of the Act and the assessee is hit by in terms of section 13(3) of the Act and the assessee is hit by provisions of section 13(1)(c)(ii) of the Act which

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX - 2 (3) (1), MUMBAI

3) read with rule 8D of the\nRules or a best judgment determination, as earlier prevailing, would become\napplicable.\"\n7.4 We have carefully perused the assessment and appellate\norders as also cited decisions(supra). From the plain reading of the\nassessment order, the satisfaction/dissatisfaction of the AO is not\ndiscernible at all. He has failed to point out any infirmity

SHREE DADAR DIGAMER JAIN MUMUKSHO MANDAL ,MUMBAI vs. CIT(EXEMPTION) WARD 2(3), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2023-24 Shri Dadar Digamber Jain The Cit (Exemption), Mumukshu Mandal, Ward-2(3), 271/293, 271/293, Vs. Mumbai. N.C. Kelkar Road, Opp: Shivaji Park, P.O. Dadar (West) Mumbai-400028. Pan : Aacts8044A (Appellant) (Respondent) For Assessee : Shri A.N. Shah For Revenue : Shri Annavaram Kosuri Date Of Hearing : 11-06-2025 Date Of Pronouncement : 15-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld.Addl/Jcit(A)-2, Delhi [„Ld.Cit(A)‟], Dated 05-03-2025, Pertaining To Assessment Year (Ay) 2023-24, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

trust or the institution. There has been an amendment to sub-section (3) by the Finance Act, 2022, w.e.f. 1st April, 2023 and it is therefore relevant to look at the un-amended provisions and the amendment which has been brought in by the Finance Act, 2022. 15. The provisions of sub-section (3) to section 11, prior

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-2(1), MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

charitable or business institution. In view of the above provisions and the factual findings discussed in earlier paragraphs the benefit of Section 11 or Section 12 cannot be given to the assessee trust in respect of its entire income. Accordingly, the exemption u/s. 11 claimed by assessee trust is, hereby, denied.” 27. The ld. AR submitted that the provisions

SIR RATAN TATA TRUST,MUMBAI SUBURBAN vs. ADDITIONAL /JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX, NFAC, MUMBAI

In the result, both the appeals of the assessee in both AY 2014-15 and AY

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

charitable or business institution. In view of the above provisions and the factual findings discussed in earlier paragraphs the benefit of Section 11 or Section 12 cannot be given to the assessee trust in respect of its entire income. Accordingly, the exemption u/s. 11 claimed by assessee trust is, hereby, denied.” 27. The ld. AR submitted that the provisions

ITO(E)-1(1), MUMBAI, MUMBAI vs. BHAVITHA FOUNDATION, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2021-22

charitable entity holding the shares received as corpus in compliance with the provisions of section 11(1)(d) read with section in compliance with the provisions of section 11(1)(d) read with section in compliance with the provisions of section 11(1)(d) read with section 13(1)(d) of the Act and the same cannot be treated

DY. COMMISSIONER OF INCOME TAX (EXEMPTION) 2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST (SHIRDI), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

charitable purpose’ set out in Explanation (3), as explained by him in the foregoing, continued to hold ground post insertion of Section 80G(5B) of the Act. 13 A.Ys. 2015-16, 2017-18, 2018-19 Shri Sai Baba Sansthan Trust (Shirdi). 11

DY. COMMISSIONER O INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST(SHIRDI), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

charitable purpose’ set out in Explanation (3), as explained by him in the foregoing, continued to hold ground post insertion of Section 80G(5B) of the Act. 13 A.Ys. 2015-16, 2017-18, 2018-19 Shri Sai Baba Sansthan Trust (Shirdi). 11

SHREE SAI BABA SANSTHAN TRUST (SHIRDI),MUMBAI vs. DY. COMMISSIONER OF INCOME TAX (EXEMPTION) 2(1), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

charitable purpose’ set out in Explanation (3), as explained by him in the foregoing, continued to hold ground post insertion of Section 80G(5B) of the Act. 13 A.Ys. 2015-16, 2017-18, 2018-19 Shri Sai Baba Sansthan Trust (Shirdi). 11

DY. COMMISSIONER O INCOME TAX (EXEMPTION)-2(1), MUMBAI vs. SHREE SAI BABA SANSTHAN TRUST(SHIRDI), MUMBAI

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

charitable purpose’ set out in Explanation (3), as explained by him in the foregoing, continued to hold ground post insertion of Section 80G(5B) of the Act. 13 A.Ys. 2015-16, 2017-18, 2018-19 Shri Sai Baba Sansthan Trust (Shirdi). 11

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

3) The persons referred to in clause (c) of sub-section (1) and sub-section (2) are the following namely: (a) the author of the trust or the founder of the institution; ITA Nos. 1828 to 1831/Mum/2022 Mumbai Education Trust; A.Y. 08-09 to 11-12 (b) any person who has made a substantial contribution to the trust or institution

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

3) The persons referred to in clause (c) of sub-section (1) and sub-section (2) are the following namely: (a) the author of the trust or the founder of the institution; ITA Nos. 1828 to 1831/Mum/2022 Mumbai Education Trust; A.Y. 08-09 to 11-12 (b) any person who has made a substantial contribution to the trust or institution

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

3) The persons referred to in clause (c) of sub-section (1) and sub-section (2) are the following namely: (a) the author of the trust or the founder of the institution; ITA Nos. 1828 to 1831/Mum/2022 Mumbai Education Trust; A.Y. 08-09 to 11-12 (b) any person who has made a substantial contribution to the trust or institution

DY.CIT (E) -2(1) , MUMBAI vs. MUMBAI EDUCATIONAL TRUST, MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

3) The persons referred to in clause (c) of sub-section (1) and sub-section (2) are the following namely: (a) the author of the trust or the founder of the institution; ITA Nos. 1828 to 1831/Mum/2022 Mumbai Education Trust; A.Y. 08-09 to 11-12 (b) any person who has made a substantial contribution to the trust or institution

SARVAJANIK SEVA TRUST ,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Assessment Year: 2019-20

charitable trust in August 1975 under section 12A(a) of the ITA. In August 1975 it had filed prescribed Form 10A as required under section 12A(a) of the ITA. Vide communication dated 15.03.1976 the Trust was informed that the said application had been entered at Sr No TR/10925 in the Register of Applications under section

TATA SOCIAL WELFARE TRUST,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Assessment Year: 2019-20

charitable trust in August 1975 under section 12A(a) of the ITA. In August 1975 it had filed prescribed Form 10A as required under section 12A(a) of the ITA. Vide communication dated 15.03.1976 the Trust was informed that the said application had been entered at Sr No TR/10925 in the Register of Applications under section

TATA EDUCATION TRUST,MUMBAI vs. PR CIT 17, MUMBAI

charitable trust in August 1975 under section 12A(a) of the ITA. In August 1975 it had filed prescribed Form 10A as required under section 12A(a) of the ITA. Vide communication dated 15.03.1976 the Trust was informed that the said application had been entered at Sr No TR/10925 in the Register of Applications under section

R D TATA TRUST,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Assessment Year: 2019-20

charitable trust in August 1975 under section 12A(a) of the ITA. In August 1975 it had filed prescribed Form 10A as required under section 12A(a) of the ITA. Vide communication dated 15.03.1976 the Trust was informed that the said application had been entered at Sr No TR/10925 in the Register of Applications under section

JAMSETJI TATA TRUST ,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Assessment Year: 2019-20

charitable trust in August 1975 under section 12A(a) of the ITA. In August 1975 it had filed prescribed Form 10A as required under section 12A(a) of the ITA. Vide communication dated 15.03.1976 the Trust was informed that the said application had been entered at Sr No TR/10925 in the Register of Applications under section