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 Trust to be a Director in a company in which the Trust holds shares also holds a fiduciary relationship with the Trust and fiduciary duty towards the nameless, faceless beneficiaries of those Trusts". (Para 19.24 in page 334 of PB) Therefore in our considered view there is merit in the submission that the right to nominate persons

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES,MUMBAI vs. DCIT (E) , MUMBAI

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2018-19

charitable organization and accordingly. provisions of section 145 of the Act mandating following of cash or mercantile system of accounting is not applicable in the appellant's case, which is wrong and contrary to the facts of the case, the provisions of the Income Tax Act, 1961, and Rules made thereunder. (iv) CIT(A) erred in observing that: a) there

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX EXEMPTION -1(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Credit Guarantee Fund Trust Deputy Commissioner Of For Micro & Small Enterprises, Income Tax, Exemption-1(1), 1St Floor, Vs. Mtnl Tel. Exch. Building, Sidbi Swavalamban Bhavan, Cumballa Hills, Pedder Road, Avenue 3, Lane 2, G-Block, Mumbai-400026. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan : Aaatc2613D (Appellant) (Respondent) For Assessee : Shri Shailesh Shah & Shri Jay Dharod For Revenue : Shri R.A. Dhyani, Cit-Dr Date Of Hearing : 04-09-2025 Date Of Pronouncement : 15-09-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Pertaining To Assessment Year (Ay) 2018-19, Wherein The Assessee Has Taken The Following Grounds Of Appeal: “(1) On The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals) [Ld. Cit(A)], Nfac Has Erred In Confirming The Order Of Levying Penalty U/S 270A Of The Act Of Rs. 293,63,60,258/- On 2 Disallowances Made In The Assessment Order Passed U/S 143(3) R.W.S 144B Of The Act Without Appreciating The Fact That The Hon'Ble Itat, Mumbai Has Fully Deleted The Said Disallowances & Reasons Assigned By Him For Doing So Are Wrong & Contrary To The Facts & Circumstances Of The Case, Provisions Of The Act & Income Tax Rules, 1962 ("The Rules") Made Thereunder. The Appellant Prays That The Penalty U/S 270A Of The Act Of Rs. 293,63,60,258/- Be Deleted. The Appellant Craves Leave To Add, Amend, Alter, Modify And/Or Delete All Or Any Of The Above Grounds Of Appeal, On Or Before The Date Of Hearing.”

charitable activities, hence not entitled for benefit of section 11 & 12 of the Act”, are not sustainable, hence set aside. Ground No. 2 is determined in favour of the assessee. Ground No.3 21. During the year under consideration the assessee trust has claimed provision for guarantee claims to the tune of Rs.13,14,84,00,000/-. During the year under

FAYZ E HUSAYNI TRUST,MUMBAI vs. NATIONAL FACELESS APPEAL CENTRE (NAFC) DELHI , MUMBAI

In the result, appeal filed by the assessee is allowed

Charitable Trust, no tax is\npayable in view of the provisions of Section 11 and the error\ncommitted does not have any impact on the revenue In other\nwords, there is no revenue loss.\n(iii)\nAs stated earlier, the error / mistake is bonafide and\nunintentional and the same has been rectified even before the\nassessment order was passed

PODAR LITERACY AND EDUCATION TRUST,BANGALORE vs. DCIT CENTRAL CIRCLE - 1(4), MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

270A of the Act.\n2. The assessee before us is a public charitable trust,\nregistered under section 12AA(1)(b)(i) of the Act and also

NARROTAM MORARJEE INSTITUTE OF SHIPPING,MUMBAI vs. ITO (EXEMPTION)WARD 2(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19 Narrotam Morarjee Institute Of National Faceless Shipping, Mumbai Assessment Appeal Centre 76 – Jolly Maker, Chambers – 2, (Nfac) Office Of The Vs. Vivek Shah, Mumbai, Nariman Commissioner Of Income Point S.O.-400021 Tax, Appeal, Addl/Jcit(A) Delhi (Pan : Aaatn0042R) (Appellant) (Respondent) Present For: Assessee : Shri Nishit Gandhi, Advocate Revenue : Shri Leyaqat Ali Afaqui, Sr. Dr Date Of Hearing : 18.11.2025 Date Of Pronouncement : 16.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2025- 26/1078465227(1) Dated 14.07.2025 Passed Against The Penalty Order U/S. 270A Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Ay 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. In The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeals Centre, Delhi ["The Cit (A)") U/S 250 Of The Income Tax Act, 1961 ["The Act For Short Erred In Confirming The Penalty U/S 270A Of The Act Passed

charitable trust and its entire income is exempt from tax u/s 11 of the Act since the past several years: b) The penalty u/s 270A as levied by the Ld. AO is without a fair and judicious exercise of discretion, without granting a fair and reasonable opportunity of being heard and is therefore contrary to law and deserves

INTERNATIONAL SPECIALTY PRODUCTS (INDIA) PRIVATE LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 15(1)(2), MUMBAI, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Smt. Renu Jauhri

270A of the Act. 5. General 5.1 Each one of the above grounds of appeal is without prejudice to the other. 5.2 The Appellant craves leave to add to, alter, amend, vary, omit or substitute any of the aforesaid grounds of appeal or add a new ground or grounds of appeal at any time before or at the time

WNS GLOBAL SERVICES PRIVATE LIMITED,MUMBAI vs. ASESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, NEW DELHI, NEW DELHI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

270A of the Act. The Appellant craves leave to add, alter, omit or substitute at any time before or at the time of the appeal, to enable accordance with law.” 2. The assessee, a company domiciled and incorporated in India, is engaged in providing a range of Business Process Management Services (BPMS), including back-office administration, data management, and contact

M/S. SONATA INFORMATION,MUMBAI vs. CIT CIRCLE 3(4), MUMBAI

Accordingly, disallowance of INR made by the Assessing Officer is deleted and Ground No.1 & 2 raised by the Assessee are allowed

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Income Tax Act, 1961 for under reporting the income in its ITR for the year under consideration is initiated separately. (Addition: Rs. 67,15.972/-)” 4. Being aggrieved, the Assessee carried the issue in appeal before the CIT(A). However, the CIT(A) agreed with the Assessing Officer and declined to grant any relief to the Assessee

DY. COMMISSIONER OF INCOME TAX(EXEMPTIONS)-2(1), MUMBAI, MUMBAI vs. SWAMI VIVEKANAND MEDICAL MISSION, MUMBAI

In the result, both the appeals of the Revenue are dismissed

Bench: Smt. Beena Pillai & Shri Prabhash Shankarassessment Year: 2020-21 & Assessment Year: 2020-21 Dy. Commissioner Of Income Swami Vivekanand Tax (Exemptions)-2(1), Medical Mission Room No. 608, 6Th Floor, Peddar C/O Sanjivani Hospital, Vs. Road, Cumbala Hill, Datta Mandir Road, Mumbai - 400026 Virar(W) Mumbai – 401303 Pan: Aabts9185K (Appellant) (Respondent) Present For: Assessee By : Shri Anil Sathe,Ca Revenue By : Shri Dr Kishore Dhule,Cit(Dr) Date Of Hearing : 28.10.2024 Date Of Pronouncement : 19.11.2024 O R D E R Per : Prabhash Shankar: The Above Two Appeals Filed By The Revenue Emanate From The Appellate Order Passed By The Ld. Cit(A)/National Faceless Appeal Centre (Nfac), Delhi, With Regard To The Assessment/Penalty Orders Passed Under Section 143(3) & 270A Of The Income Tax Act 1961, (In Short ‘The Act’) For The A.Y. 2020-21. 2. We Take Up The Quantum Appeal First Relating To Assessment Order In Ita No.3531/M/2024 Assessment Year: 2020-21. The Revenue Has Raised Following Grounds Of Appeal :

section 143(3) and 270A of the Income Tax Act 1961, (in short ‘the Act’) for the A.Y. 2020-21. 2. We take up the quantum appeal first relating to assessment order in ITA No.3531/M/2024 Assessment Year: 2020-21. The Revenue has raised following grounds of appeal : “1. Whether on the facts and circumstance of the case

DY. COMMISSIONER OF INCOME TAX(EXEMPTIONS)-2(1), MUMBAI, MUMBAI vs. SWAMI VIVEKANAND MEDICAL MISSION, MUMBAI

In the result, both the appeals of the Revenue are dismissed

Bench: Smt. Beena Pillai & Shri Prabhash Shankarassessment Year: 2020-21 & Assessment Year: 2020-21 Dy. Commissioner Of Income Swami Vivekanand Tax (Exemptions)-2(1), Medical Mission Room No. 608, 6Th Floor, Peddar C/O Sanjivani Hospital, Vs. Road, Cumbala Hill, Datta Mandir Road, Mumbai - 400026 Virar(W) Mumbai – 401303 Pan: Aabts9185K (Appellant) (Respondent) Present For: Assessee By : Shri Anil Sathe,Ca Revenue By : Shri Dr Kishore Dhule,Cit(Dr) Date Of Hearing : 28.10.2024 Date Of Pronouncement : 19.11.2024 O R D E R Per : Prabhash Shankar: The Above Two Appeals Filed By The Revenue Emanate From The Appellate Order Passed By The Ld. Cit(A)/National Faceless Appeal Centre (Nfac), Delhi, With Regard To The Assessment/Penalty Orders Passed Under Section 143(3) & 270A Of The Income Tax Act 1961, (In Short ‘The Act’) For The A.Y. 2020-21. 2. We Take Up The Quantum Appeal First Relating To Assessment Order In Ita No.3531/M/2024 Assessment Year: 2020-21. The Revenue Has Raised Following Grounds Of Appeal :

section 143(3) and 270A of the Income Tax Act 1961, (in short ‘the Act’) for the A.Y. 2020-21. 2. We take up the quantum appeal first relating to assessment order in ITA No.3531/M/2024 Assessment Year: 2020-21. The Revenue has raised following grounds of appeal : “1. Whether on the facts and circumstance of the case

MAJLIS E KHUDDAMUL MADARI S,MUMBAI vs. ITO EXEM. WARD 2(1), MUMBAI

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

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhanassessment Year : 2017-18 Majlis E Khuddamul Madari S, Ito(Exem), Ward-2(1), 14, Uasim Mansion, Room No. 512, 5Th Floor, Koleueheri Village, Vs. Piramal Chambers, Chinchpada, Lal Baug, Parel, Kalina, Mumbai-400012. Mumbai-400098. Pan : Aaaam0694F (Appellant) (Respondent) For Assessee : None For Revenue : Shri Surendra Mohan, Sr.Dr Date Of Hearing : 16-10-2025 Date Of Pronouncement : 27-10-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 25-06-2025, Pertaining To Assessment Year (Ay) 2017-18, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

charitable/ religious in nature and the same is allowable in the case of assessee who got registered u/s. 12A of the Act. The assessee was asked to submit copy of registration u/s. 12A of the Act, however, the assessee has not submitted the same. Therefore, the assessee is not eligible for claim of exemption u/s. 11 of the act. Further

THE CATHEDRAL VIDYA TRUST,MUMBAI vs. ADDITIONAL-JOINT-DEPUTY-ASSISTANT COMMISSIONER OF INCOME TAX - INCOME TAX OFFICER , DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19

270A on account of under reporting of income in consequence of misreporting thereof. 3. Brief facts of the case are that assessee is a trust registered as a charitable organisation with Charity Commissioner and CIT(E), Mumbai, u/s.12A for the registration No.TR/42158, dated 31.03.2009 and with Charity Commissioner, Mumbai vide registration No. E- 25131(Bombay). Assessee also obtained approval