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 and religious purpose, has incurred religious expenditure which is less than 5% of the total expenses of the Trust. In such a case, the trust may be eligible for certificate u/s 80G of the Act and at the same time would not be liable to be taxed for the anonymous donations received by virtue of Section 115BBC

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 and religious purpose, has incurred religious expenditure which is less than 5% of the total expenses of the Trust. In such a case, the trust may be eligible for certificate u/s 80G of the Act and at the same time would not be liable to be taxed for the anonymous donations received by virtue of Section 115BBC

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 and religious purpose, has incurred religious expenditure which is less than 5% of the total expenses of the Trust. In such a case, the trust may be eligible for certificate u/s 80G of the Act and at the same time would not be liable to be taxed for the anonymous donations received by virtue of Section 115BBC

M/S MANTHAN INC,MUMBAI vs. INCOME TAX CIRCLE, 19(2) MUMBAI, MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14 & Assessment Year: 2014-15 M/S Manthan Inc, Acit Cir. 19(2), Rani Bldg., V.P. Road, Tardeo, Vs. Mumbai-400 004. Mumbai. Pan No. Aakfm 6011 D Appellant Respondent : Assessee By Mr. Dilip Diwan, Ar Revenue By : Smt. Mahita Nair, Dr : Date Of Hearing 12/01/2023 : Date Of Pronouncement 19/01/2023

Charitable Trust and also to afford an opportunity of cross also to afford an opportunity of cross-examination to the assessee. examination to the assessee. However, the notice sent u/s However, the notice sent u/s 133(6) of the Act were returned 133(6) of the Act were returned unserved. In the circumstances, the Assessing Officer asked the unserved

M/S MANTHAN INC ,MUMBAI vs. INCOME TAX CIRCLE, 19(2), MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14 & Assessment Year: 2014-15 M/S Manthan Inc, Acit Cir. 19(2), Rani Bldg., V.P. Road, Tardeo, Vs. Mumbai-400 004. Mumbai. Pan No. Aakfm 6011 D Appellant Respondent : Assessee By Mr. Dilip Diwan, Ar Revenue By : Smt. Mahita Nair, Dr : Date Of Hearing 12/01/2023 : Date Of Pronouncement 19/01/2023

Charitable Trust and also to afford an opportunity of cross also to afford an opportunity of cross-examination to the assessee. examination to the assessee. However, the notice sent u/s However, the notice sent u/s 133(6) of the Act were returned 133(6) of the Act were returned unserved. In the circumstances, the Assessing Officer asked the unserved

ITO (E) 2(3), MUMBAI vs. SRI SRI RADHA DAMODAR CHARITABLE TRUST, MUMBAI

In the result, appeal filed by Revenue is dismissed

Bench: Shri Shamim Yahya & Shri Pawan Singhito (E)-2(3) Shri Radha Damodar Charitable 513, 5Th Floor, Trust, Hare Krishna Land, Juhu, Vs. Piramal Chambers, Lalbaug, Mumbai-400049 Mumbai-12. Pan:Aafts2570L (Appellant) (Respondent) Revenue By : Shri Ram Tiwari (Dr) Assessee By : Sh. Nishant Thakkar With Ms. Jasmin Amalsadwala- Advocates. Date Of Hearing : 20.03.2018 Date Of Pronouncement : 04.04.2018 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Revenue Under Section 253 Of Income Tax Act (‘The Act’) Is Directed Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-1

section 11 of the Act. The ld. DR for the Revenue supported the order of Assessing ITA No. 3809/Mum/2016 - Shri Radha Damodar Charitable Trust Officer. The ld. DR further submits that the Assessing Officer has clearly brought out on record that the assessee has a sale of Rs. 7,07,25,469/- against the total purchase

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

RATAN TATA TRUST,MUMBAI vs. CIT (E), MUMBAI

In the result, the appeal is allowed

charitable objects. Virtually, all the shares are held by it today. The position is continuing for 4 decades. The assessee has been consistently granted the exemption u/s. 11 of the Income-tax Act. Therefore, calling upon the assessee to demonstrate the fulfilment of conditions is grossly unfair. In this regard, it is stated that: a) It is a settled judicial

ROSHAN CHARITABLE TRUST,MUMBAI vs. CIT (E), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am Roshan Charitable Trust, C/O 29Th Commissioner Of Income-Tax Bank Street, Sonawala Building-Fort, 6Th Vs. (Exemptions), Floor, Piramal Mumbai-400023 Chambers, Parel, Mumbai-400012. Pan: Aactr2405A .. Appellant Respondent .. P.J. Pardiwala, Ar Assessee By Revenue By .. K.B. Shukla (Citdr.) Date Of Hearing .. 27-10-2016 .. Date Of Pronouncement 04-11-2016

Section 12AA (1) (b), a Trust is to be granted registration if the Commissioner is satisfied about the objects of the Trust and the genuineness of its activities. Both these requirements are cumulative and not alternative. The satisfaction of the registering authority cannot be a subjective satisfaction based on whim or caprice. It has to be a bona tide

J.R.D TATA TRUST ,MUMBAI vs. CIT (E), MUMBAI

In the result, the appeal is allowed

charitable objects. Virtually, all the shares are held by it today. The position is continuing for 4 decades. The assessee has been consistently granted the exemption u/s. 11 of the Income-tax Act. Therefore, calling upon the assessee to demonstrate the fulfilment of conditions is grossly unfair. In this regard, it is stated that: a) It is a settled judicial

ITO (E)-II(1), MUMBAI vs. KALYANI CARTIABLE TRUST, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri R.C.Sharma, Am & Shri Ravish Sood, Jm (Assessment Year :2010-11 Ito (E)-Ii(1), Mumbai Vs. M/S. Kalyani Charitable Trust, C/O. Ravi Communication, Jj Hospital Campus, Byculla, Mumbai- 400008 Pan/Gir No. Aaatk3179R Appellant) .. Respondent)

section 13(2)(g) r.w.s. 13(3)(cc) of the I. T. Act, as above, the exemption u/s 11 is denied to the trust on the said amount. 5.2 The appellant has submitted before the AO also that - We are enclosing herewith following documents as required by you. 8 M/s. Kalyani Charitable Trust 1) ROC Annual Return of Mls Kalyani

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.”

70,216/- vide order dated 14-04-2021 passed under section 143(3) read with section 144(3A) read with section 143(3B) of the Act. The penalty proceedings u/s 270A read with 274 were separately initiated stating that the assessee has unreported the income in consequence of misreporting of income. 3. The assessee carried the matter in appeal before

ITO (E) 2(3), MUMBAI vs. SRI SRI RADHA DAMODAR CHARITABLE TRUST, MUMBAI

In the result, appeal filed by Revenue is dismissed

Bench: Shri B.R. Baskaran & Shri Pawan Singhito (E)-2(3) Shri Radha Damodar Charitable 513, 5Th Floor, Trust, Hare Krishna Land, Juhu, Vs. Piramal Chambers, Lalbaug, Mumbai-400049 Mumbai-12. Pan:Aafts2570L (Appellant) (Respondent) Ddit (E) I (1) Shri Radha Damodar Charitable 504,5Th Floor, Trust, Hare Krishna Land, Juhu, Vs. Piramal Chambers, Lalbaug, Mumbai-400049 Mumbai-12. Pan:Aafts2570L (Appellant) (Respondent)

charitable purposes of the trust and accordingly we are inclined to uphold the findings of the ld. CIT(A) in allowing both the claim of the assessee. The grounds taken by the Revenue are, therefore, rejected.” 6.The Hon'ble Jurisdictional High Court 'in the case of Director of Income-tax Vs. Womens India Trust

DCIT (EXEMPTIONS)-2(1), MUMBAI vs. TATA EDUCATION AND DEVEOPMENT TRUST, MUMBAI

In the result, the appeal filed by the assessee is allowed in the terms indicated above

Trust and also within the Meaning of charitable purpose defined under Section 2(15) of the Act. Further, as narrated above, the Tata scholarship has definitely helped far more Indian students (than previously possible) A providing an opportunity to significantly gain from Cornell's expertise. 3.21 Given the same, TEDT wishes to reiterate that Tata Scholarship has definitely promoted international

TATA EDUCATION AND DEVEOPMENT TRUST,MUMBAI vs. ACIT(EXP)-2(1) NOW ASSESSED BY DCIT (EXEMPTIONS)-2(1), MUMBAI

In the result, the appeal filed by the assessee is allowed in the terms indicated above

Trust and also within the Meaning of charitable purpose defined under Section 2(15) of the Act. Further, as narrated above, the Tata scholarship has definitely helped far more Indian students (than previously possible) A providing an opportunity to significantly gain from Cornell's expertise. 3.21 Given the same, TEDT wishes to reiterate that Tata Scholarship has definitely promoted international

TATA EDUCATION AND DEVEOPMENT TRUST,MUMBAI vs. ACIT(EXP)-2(1) NOW ASSESSED BY DCIT (EXEMPTIONS)-2(1), MUMBAI

In the result, the appeal filed by the assessee is allowed in the terms indicated above

Trust and also within the Meaning of charitable purpose defined under Section 2(15) of the Act. Further, as narrated above, the Tata scholarship has definitely helped far more Indian students (than previously possible) A providing an opportunity to significantly gain from Cornell's expertise. 3.21 Given the same, TEDT wishes to reiterate that Tata Scholarship has definitely promoted international

TATA EDUCATION TRUST ,MUMBAI vs. ASSISTANT COMMISSIIONER OF INCOME TAX CIRCLE 17(3), MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

charitable trust registered u/s. 12A of the Act and for alleged violation in conditions of Sections 13(1)(d) and 13(2)(h) of the Act have not only denied exemption u/s. 11 of the Act but have also rejected assessee’s claim of exemption u/s. 10(34) and 10(35) of the Act. We find, while considering identical nature

TATA EDUCATION TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-CIRCLE 2(1), MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

charitable trust registered u/s. 12A of the Act and for alleged violation in conditions of Sections 13(1)(d) and 13(2)(h) of the Act have not only denied exemption u/s. 11 of the Act but have also rejected assessee’s claim of exemption u/s. 10(34) and 10(35) of the Act. We find, while considering identical nature