MAHANSARIA ENTERPRISES PVT LTD,MUMBAI vs. PR. CIT, MUMBAI-5, MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2020-21 Mahansaria Enterprises Private The Principal Commissioner Of Limited, Income Tax (Pcit), 301-304, 3Rd Floor, Vs. Room No. 515, 5Th Floor, Peninsula Chambers, Aayakar Bhavan, Peninsula Corporate Park, Maharshi Karve Road, G.K. Marg, Lower Parel West, Mumbai-400020 Mumbai-400026 Pan : Aaacy1568L (Appellant) (Respondent) For Assessee : Shri Vipul Joshi, Adv. & Prashant Bhumare For Revenue : Shri Satyaprakash R. Singh, Cit-Dr Date Of Hearing : 14-05-2025 Date Of Pronouncement : 11-06-2025 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. Principal Commissioner Of Income Tax, Mumbai-5 [„Ld.Pcit‟] U/S. 263 Of The Income Tax Act, 1961 („The Act‟), Dated 17-03-2025, Pertaining To Assessment Year (Ay) 2020-21, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

ix. Sequel Logistics Private Ltd. vs. PCIT [(Ι.Τ.Α. No 1114/Ahd/2024)] x. American Express (India) P. Ltd. v. PCIT [(2024) 208 ITD 564 (Delhi - Trib.)] xi. ACIT vs. Sikka Ports and Terminals Ltd [2025] 173 taxmann.com 366 (Mumbai - Trib.)] xii. American Express (India) P. Ltd. vs. PCIT [2024] 166 taxmann.com 91 (Delhi-Trib.) 12 xiii. Interglobe Technology Quotient

SOU DWARKABAI SHASTRI PATWARDHAN TRUST,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI , MUMBAI

Appeal is allowed for statistical purposes

Bench: Shri Satbeer Singh Godara & Shri Omkareshwar Chidaraassessment Year: 2025-26

80G. (1) In computing the total income of an assessee, there shall be deducted, in accordance with and subject to the provisions of this section,— (i) … (ii) ….. (2) The sums referred to in sub-section (1) shall be the following, namely :— (a) …….. (b) ………….. (c) ………………… (d)…………. (4) ………………………. (5) This section applies to donations to any institution or fund referred

NILESH KULKARNI FOUNDATION ,MUMBAI vs. COMMISSIONER OF INCOME TAX ( EXEMPTIONS), MUMBAI

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

80G has to considered as per the provisions of subsection 6 Nilesh Kulkarni Foundation (5) of the said section, which in the present case has not been carried out by the CIT(E). The relevant provisions read as under – (5) This section applies to donations to any institution or fund referred to in sub-clause (iv) of clause

SOLA HAKIM MEDICAL RESEARCH TRUST, MUMBAI vs. DIT (E), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri M.Balaganesh, Am & Shri Amarjit Singh, Jm Sola Hakim Medical Vs. The Director Of Income- Research Trust Tax(Exemption), Mumbai 9, Hamton Court Colaba, Mumbai – 400 005 Pan/Gir No.Aacts2195J (Appellant) .. (Respondent)

charitable purposes for the previous year beginning on the 1st day of April, 2008 and ending on the 31st day of March, 2009; and (b) Approved under the said clause (vi) for the previous year beginning on the 1st day of April 2008 and ending on the 31st day of March, 2009) 5. We find that

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)

80G of the Act. Objects of the trust include promotion of education & allied activities. Accordingly, trust is running school, college of engineering, pharmacy, management etc. During F.Y. 2009-10 assessee received donations towards its Building Fund from Mr. Nilesh J. Thakur (Proprietor of PRS Enterprises and PRS Developers) to the tune of Rs. 6.00 Cr. The donations were duly acknowledged

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CENT. CIR 1(40, MUMBAI vs. PODAR EDUCATION AND SPORTS TRUSTS, BENGALURU

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4) , MUMBAI vs. PODAR EDUCATION & SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR1(4) , MUMBAI vs. PODAR EDUCATION AND SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CENT. CIR 1(4) , MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4) , MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CENT. CIR.1(4), MUMBAI vs. PODAR EDUCATION & SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CENT. CIR1(4) , MUMBAI vs. PODAR EDUCATION & SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

ST. JOSEPH'S EDUCATION AND MEDICAL RELIEF SOCIETY ,MUMBAI vs. ASSTT. DIRECTOR OF INCOME TAX -(E)-II(1), MUMBAI

In the result appeals filed by the assessee for all the years\nunder consideration stands allowed

80G of the act with effect from 01/04/1992. It is\nsubmitted that as on date, both these certificates are valid and in\nforce.\nIt is submitted that, the assessee is running 12 institutions\nestablished in different parts of the country covering hospitals,\neducational institution, imparting education to pre-primary,\nprimary and high school etc. It is submitted that, all these

DCIT CIR 1(4) , MUMBAI vs. ANANDILAL & GANESH PODAR SOCIETY, MUMBAI

In the result, all the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

80G of the Act of CIT-II, Thane of Karnala Charitable Trust 19 ITA.No. 713/Mum/2020 (A.Y.2011-12) ITA NOs. 1791, 1790, 1792 & 1889/MUM/2021& Other appeals Anandilal and Ganesh Podar Society & other group concerns 15:32 To sum up, on the issue of siphoning of funds by the Donee Trusts, there is no adverse observation by the AO in the Remand Report

DCIT CIR 1(4) , MUMBAI vs. ANANDILAL & GANESH PODAR SOCIETY, MUMBAI

In the result, all the appeals of the revenue are dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

80G of the Act of CIT-II, Thane of Karnala Charitable Trust 19 ITA.No. 713/Mum/2020 (A.Y.2011-12) ITA NOs. 1791, 1790, 1792 & 1889/MUM/2021& Other appeals Anandilal and Ganesh Podar Society & other group concerns 15:32 To sum up, on the issue of siphoning of funds by the Donee Trusts, there is no adverse observation by the AO in the Remand Report