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

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

House, Homi Mody Street Mumbai 400 001 Sir, Sub: Show cause for cancellation u/s 12AA of registration granted under section 12A to Navajibai Ratan Tata Trust- reg- Kindly refer to the above. 2. Navajibai Ratan Tata Trust was granted registration under section 12 A of the Income Tax Act, by the Commissioner of Income Tax, Bombay City-IV, Bombay vide

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

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

House, Homi Mody Street Mumbai 400 001 Sir, Sub: Show cause for cancellation u/s 12AA of registration granted under section 12A to Navajibai Ratan Tata Trust- reg- Kindly refer to the above. 2. Navajibai Ratan Tata Trust was granted registration under section 12 A of the Income Tax Act, by the Commissioner of Income Tax, Bombay City-IV, Bombay vide

NAVAJBAI RATAN TATA TRUST ,MUMBAI vs. PR CIT 17, MUMBAI

Bench: Us, Are As Follows: Page 2 Of 47 1 A) The Impugned Order Dated 31.10.2019 Passed By The Learned Principal Commissioner Of Income-Tax-17 ('Pcit') Under Section 12Aa(3)/(4) Of The Income-Tax Act, 1961 ('Ita') Cancelling The Registration Of The Appellant Is Without Jurisdiction And, Hence, Void Ab Initio.

House, Homi Mody Street Mumbai 400 001 Sir, Sub: Show cause for cancellation u/s 12AA of registration granted under section 12A to Navajibai Ratan Tata Trust- reg- Page 12 of 47 Kindly refer to the above. 2. Navajibai Ratan Tata Trust was granted registration under section 12 A of the Income Tax Act, by the Commissioner of Income Tax, Bombay

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

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

House, Homi Mody Street Mumbai 400 001 Sir, Sub: Show cause for cancellation u/s 12AA of registration granted under section 12A to Navajibai Ratan Tata Trust- reg- Kindly refer to the above. 2. Navajibai Ratan Tata Trust was granted registration under section 12 A of the Income Tax Act, by the Commissioner of Income Tax, Bombay City-IV, Bombay vide

DY CIT CC 1(4), MUMBAI vs. M/S ULTRATECH CEMENT LTD , MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Ultratech Cement Limited V. Dcit, Central Circle-1(4) Ahura Centre, ‘B’ Wing 2Nd Floor Room No. 902, 9Th Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Dcit, Central Circle-1(4) V. M/S. Ultratech Cement Limited Room No. 902, 9Th Floor Ahura Centre, ‘B’ Wing 2Nd Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

12A) of section 80IA of the IT Act, merely neutralises applicability of sub-section (12) and does not disentitle the successor entities to claim deduction in accordance with section 80IA of the IT Act. Accordingly, AO is directed to allow the deduction as claimed by the assessee with respect to eligible units acquired from SCL. Accordingly, Ground no.1

ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CC 1(4), MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Ultratech Cement Limited V. Dcit, Central Circle-1(4) Ahura Centre, ‘B’ Wing 2Nd Floor Room No. 902, 9Th Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Dcit, Central Circle-1(4) V. M/S. Ultratech Cement Limited Room No. 902, 9Th Floor Ahura Centre, ‘B’ Wing 2Nd Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

12A) of section 80IA of the IT Act, merely neutralises applicability of sub-section (12) and does not disentitle the successor entities to claim deduction in accordance with section 80IA of the IT Act. Accordingly, AO is directed to allow the deduction as claimed by the assessee with respect to eligible units acquired from SCL. Accordingly, Ground no.1

DCIT- CC- 1(4), MUMBAI vs. ULTRATECH CEMENT LTD., MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

properties, estates etc. of SCL included Rail undertakings and power plants for which SCL had been claiming tax holiday u/s 80IA. v. Upon amalgamation of SCL and vesting of its Railway undertakings at Rawan - District Raipur, at Hotgi - District Sholapur, at Shambhupura - District Chittorgarh, and at Dodaballarpur - District Bangalore, into the assessee, the assessee Company claimed a deduction of Rs.82

ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CEN CIR 1(4), MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

properties, estates etc. of SCL included Rail undertakings and power plants for which SCL had been claiming tax holiday u/s 80IA. v. Upon amalgamation of SCL and vesting of its Railway undertakings at Rawan - District Raipur, at Hotgi - District Sholapur, at Shambhupura - District Chittorgarh, and at Dodaballarpur - District Bangalore, into the assessee, the assessee Company claimed a deduction of Rs.82

DCIT -CC-1(4), MUMBAI vs. ULTRATECH CEMENT LTD. , MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

properties, estates etc. of SCL included Rail undertakings and power plants for which SCL had been claiming tax holiday u/s 80IA. v. Upon amalgamation of SCL and vesting of its Railway undertakings at Rawan - District Raipur, at Hotgi - District Sholapur, at Shambhupura - District Chittorgarh, and at Dodaballarpur - District Bangalore, into the assessee, the assessee Company claimed a deduction of Rs.82

ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CEN CIR 1(4), MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

properties, estates etc. of SCL included Rail undertakings and power plants for which SCL had been claiming tax holiday u/s 80IA. v. Upon amalgamation of SCL and vesting of its Railway undertakings at Rawan - District Raipur, at Hotgi - District Sholapur, at Shambhupura - District Chittorgarh, and at Dodaballarpur - District Bangalore, into the assessee, the assessee Company claimed a deduction of Rs.82

ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CEN CIR 1(4), MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

properties, estates etc. of SCL included Rail undertakings and power plants for which SCL had been claiming tax holiday u/s 80IA. v. Upon amalgamation of SCL and vesting of its Railway undertakings at Rawan - District Raipur, at Hotgi - District Sholapur, at Shambhupura - District Chittorgarh, and at Dodaballarpur - District Bangalore, into the assessee, the assessee Company claimed a deduction of Rs.82

DCIT - CC - 1(4), MUMBAI vs. ULTRATECH CEMENT LTD., MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

properties, estates etc. of SCL included Rail undertakings and power plants for which SCL had been claiming tax holiday u/s 80IA. v. Upon amalgamation of SCL and vesting of its Railway undertakings at Rawan - District Raipur, at Hotgi - District Sholapur, at Shambhupura - District Chittorgarh, and at Dodaballarpur - District Bangalore, into the assessee, the assessee Company claimed a deduction of Rs.82

ULTRATECH CEMENT LTD,MUMBAI vs. DCIT CEN CIR 1(4), MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

properties, estates etc. of SCL included Rail undertakings and power plants for which SCL had been claiming tax holiday u/s 80IA. v. Upon amalgamation of SCL and vesting of its Railway undertakings at Rawan - District Raipur, at Hotgi - District Sholapur, at Shambhupura - District Chittorgarh, and at Dodaballarpur - District Bangalore, into the assessee, the assessee Company claimed a deduction of Rs.82

JT. CIT (OSD)- CC - 1(4), MUMBAI vs. ULTRATECH CEMENT LTD., MUMBAI

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly allowed as indicated above

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

properties, estates etc. of SCL included Rail undertakings and power plants for which SCL had been claiming tax holiday u/s 80IA. v. Upon amalgamation of SCL and vesting of its Railway undertakings at Rawan - District Raipur, at Hotgi - District Sholapur, at Shambhupura - District Chittorgarh, and at Dodaballarpur - District Bangalore, into the assessee, the assessee Company claimed a deduction of Rs.82

AMATEUR RODERS CLUB,MUMBAI vs. ADIT (E) II(2), MUMBAI

In the result, appeal stands allowed in the terms indicated above

Bench: Shri Saktijit Deyand Shri Manoj Kumar Aggarwal

house property. Thus, it was submitted, the assessee fulfills the conditions of ‘charitable purpose’ as per 4 Amateur Riders’ Club section 2(15) of the Act, hence, eligible to claim exemption under section 11 of the Act. The Assessing Officer, however, did not find merit in the submissions of the assessee. He observed, the assessee is basically a club

CHAMBER OF INDIAN CHARITABLE TRUSTS,MUMBAI vs. PR CIT/ COMM OF INCOME TAX, MUMBAI

In the result, the appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. Nos. 2168 & 2169/Mum/2021 (निर्धारण वर्ा / Assessment Year:2022-23) Chamber Of Indian बिधम/ Pcit Charitable Trusts Mumbai-400020. Vs. Gala No.328-332, Linkway Estates, New Link Road, Malad (W), Mumbai- 400064. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaicc9627J (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri P. J. Pardiwala & Mr. Sukhsagar Syal. Revenue By: Shri Nihar Samal (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 04/07/2022 घोषणा की तारीख /Date Of Pronouncement: 28/09/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Trust Against The Imposition Of Certain Impugned Conditions In The Orders Passed By The Ld. Cit(E), Mumbai Dated 24.09.2021 & 24.05.2021, Whereby The Ld. Cit(E) Granted Registration U/S 12Ab(1)(A) Of The Income Tax Act, 1961 (Hereinafter “The Act”) & Under Clause (Iii) Of The Second Proviso To Section 80G(5) Of The Act

12A of the Act was bad in law. A.Ys.2022-23 Chamber of Indian Charitable Trust 11. Further, according to Shri Pardiwala, sub-sections (4) and (5) of the Section 12AB of the Act contained the conditions under which registration granted can be cancelled. The said provisions as they stood at the time of passing the impugned order

CHAMBER OF INDIAN CHARITABLE TRUSTS,MUMBAI vs. PR CIT/ COMM OF INCOME TAX, MUMBAI

In the result, the appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey, Jm & Shri Gagan Goyal, Am आयकर अपील सं/ I.T.A. Nos. 2168 & 2169/Mum/2021 (निर्धारण वर्ा / Assessment Year:2022-23) Chamber Of Indian बिधम/ Pcit Charitable Trusts Mumbai-400020. Vs. Gala No.328-332, Linkway Estates, New Link Road, Malad (W), Mumbai- 400064. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaicc9627J (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri P. J. Pardiwala & Mr. Sukhsagar Syal. Revenue By: Shri Nihar Samal (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 04/07/2022 घोषणा की तारीख /Date Of Pronouncement: 28/09/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Trust Against The Imposition Of Certain Impugned Conditions In The Orders Passed By The Ld. Cit(E), Mumbai Dated 24.09.2021 & 24.05.2021, Whereby The Ld. Cit(E) Granted Registration U/S 12Ab(1)(A) Of The Income Tax Act, 1961 (Hereinafter “The Act”) & Under Clause (Iii) Of The Second Proviso To Section 80G(5) Of The Act

12A of the Act was bad in law. A.Ys.2022-23 Chamber of Indian Charitable Trust 11. Further, according to Shri Pardiwala, sub-sections (4) and (5) of the Section 12AB of the Act contained the conditions under which registration granted can be cancelled. The said provisions as they stood at the time of passing the impugned order

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

House, Road), Charni Road (East), Mumbai-400026. Mumbai-400 004. PAN NO. AAFCA 3001 P Appellant Respondent : Mr. Firoz Andhyarujina Assessee by Revenue by : Mr. Surendra Mohan, Sr. DR : 01/10/2025 Date of Hearing Date of pronouncement : 24/12/2025 ORDER PER OM PRAKASH KANT, AM This appeal by the Revenue is directed against order dated 29.05.2025 passed by the Ld. Commissioner