MINERAL FOUNDATION OF GOA,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), CIRCLE - 1, MANGALORE

In the result, the appeal of the assessee is allowed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

3 Mineral Foundation of Goa v. ACIT “5.3.3 I have considered both the calculations of deduction u/s 11(1)(a) of the Act. Section 11(1)(a) refers to income derived from property held under trust wholly for charitable

PACT FOUNDATION,GOA vs. CIT, EXEMPTIONS, BENGALURU

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 311/Pan/2024 (A.Y. 2024-25) Pact Foundation, Vs Cit (Exemptions), Unity Building Annex, F1,Pirazona Moria, Bardez . Mission Road, Aldona.S.O, Bangalore-560027, Jasmine Plaza, Karnataka. North Goa-403508 . Goa. Pan .No. Aaftp2682J (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By None(Letter 4-03-2025) Revenue By Shri.Captain Pradeep Arya.Dr

3. The brief facts of the case are that, the assessee is a registered charitable trust and is undertaking charitable activities as per the registered trust deed dated 8-07-2022. The assesse was granted provisional registration under section

YAKSHIT YUVA FOUNDATION,BELAGAVI vs. CIT (EXEMPTION), BENGALORE

Appeals stands Allowed

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 233 & 234/Pan/2025 Yakshit Yuva Foundation O/O Taekwondo Master Rao, 1St Fl, Gadekar Complex, P B Road, Kakati S.O., Belagavi. Pan : Aaaty9435D . . . . . . . Appellant V/S The Commissioner Of Income Tax, Exemption, Bangalore. . . . . . . . Respondent

3. Tersely stated common facts borne out of case records are that; the assessee is a public charitable trust established on 14/11/2022 and registered on 16/11/2022. Pursuant to separate applications filed under amended provisions of the Act, the assessee Trust was accorded provisional registrations u/s 12AB r.w.s. 12A(1)(ac)(vi) and also 80G of the Act on 24/03/2023

YAKSHIT YUVA FOUNDATION,BELAGAVI vs. CIT (EXEMPTION), BENGALURU

Appeals stands Allowed

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 233 & 234/Pan/2025 Yakshit Yuva Foundation O/O Taekwondo Master Rao, 1St Fl, Gadekar Complex, P B Road, Kakati S.O., Belagavi. Pan : Aaaty9435D . . . . . . . Appellant V/S The Commissioner Of Income Tax, Exemption, Bangalore. . . . . . . . Respondent

3. Tersely stated common facts borne out of case records are that; the assessee is a public charitable trust established on 14/11/2022 and registered on 16/11/2022. Pursuant to separate applications filed under amended provisions of the Act, the assessee Trust was accorded provisional registrations u/s 12AB r.w.s. 12A(1)(ac)(vi) and also 80G of the Act on 24/03/2023

SHREE GEETA DHARM MANDAL,C/O S J KAMAT AND CO, SAKET vs. CIT(EXEMPTIONS), BANGALORE

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 288/Pan/2024 (A.Y. 2024-25) Shree Geeta Dharam Vs Cit (Exemptions), Unity Building Annex, Mandal, . Mission Road, Opp:Gram Panchayat, Bangalore-560027, Anjuna Bardez, Karnataka. Anjuna-403509 . Goa. Pan .No. Aawts4171Q (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By None(Letter 5-03-2025) Revenue By Shri.Captain Pradeep Arya.Dr

charitable activities as per the trust deed dated 30-08-2018. The assesse was 2 Shree Geeta Dharam Mandal . granted provisional registration under section 12AB of the Act in Form.no.10AC on 27-05-2021. Subsequently, as per the amended, provisions of section 12AB of the Act, The assessee for the purpose of permanent registration has uploaded e-application

RAJA BHAT AND KUMUDA FOUNDATION,BELAGAVI vs. PR.COMMISSIONER OF INCOME TAX , BELAGAVI

The appeal of the assessee is ALLOWED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2022-23 Raja Bhat & Kumuda Foundation Plot No. 4, Rs No1368, Kumudini, Sadashiv Nagar, Belgavi-590001 Pan:Aajcr6351B . . . . . . . Appellant

Charitable Trust Vs CIT(E)’[2024, 169 taxmann.com 543 (Bom)], ‘Shree Bhairav Seva Samiti Vs ITO’[2023, 101 ITR 708(Mum)] & ‘Sirur Shikshan Prasarak Mandal Vs ACIT’ (supra). In absence of anything contrary brought on record by the Revenue, there is no reasons to divert from settled legal position. Therefore, respectfully following judicial precedents(supra), we set-aside the impugned

FABRICA DA IGREJA DE PARRA,PARRA vs. INCOME TAX OFFICER, (EXEMPTION), WARD - 1, PANAJI

Appeals are allowed for statistical purposes

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 220 & 221/Pan/2025 Fabrica Da Igreja De Parra C/O, St. Annee Church Parra, Bardez, North Goa-403510 Pan : Aaatf2744C . . . . . . . Appellant V/S Income Tax Officer, Ward-1, Panaji . . . . . . . Respondent Appearances Assessee By : Ms Jinita Chatterjee [‘Ld. Ar’] Revenue By : Mr Azar Zain [‘Ld. Dr’] Date Of Conclusive Hearing : 11/02/2026 Date Of Pronouncement : 13/02/2026 Order Per G. D. Padmahshali; By Present Twin Appeals, The Assessee Impugns Separate Orders Of Rejection Passed U/S 12Ab(3) Of The Income Tax Act [In Short ‘The Act’] By The Commissioner Of Income Tax, Exemption, Bengaluru [In Short ‘Cit(E)’] Vide Din & Order No. Itba/Exm/F/Exm45/2025- 16/1077247685(1) Dt. 20/06/2025 & 1077646854(1) Dt. 24/06/2025. Itat-Panaji Page 1 Of 9

trust established in accordance with applicable law & in operation as such [Constitution/Establishment] (b) whether all the entries of object clause are in consonance with the ‘charitable purpose’ as defined by section 2(15) of the Act [Objects] (c) whether there exist any implied or express provision in the constitutional & other administrative ITAT-Panaji Page 6 of 9 Fabrica Da Igreja

FABRICA DA IGREJA DE PARRA,PARRA vs. INCOME TAX OFFICER, (EXEMPTION) WARD -1, PANAJI

Appeals are allowed for statistical purposes

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 220 & 221/Pan/2025 Fabrica Da Igreja De Parra C/O, St. Annee Church Parra, Bardez, North Goa-403510 Pan : Aaatf2744C . . . . . . . Appellant V/S Income Tax Officer, Ward-1, Panaji . . . . . . . Respondent Appearances Assessee By : Ms Jinita Chatterjee [‘Ld. Ar’] Revenue By : Mr Azar Zain [‘Ld. Dr’] Date Of Conclusive Hearing : 11/02/2026 Date Of Pronouncement : 13/02/2026 Order Per G. D. Padmahshali; By Present Twin Appeals, The Assessee Impugns Separate Orders Of Rejection Passed U/S 12Ab(3) Of The Income Tax Act [In Short ‘The Act’] By The Commissioner Of Income Tax, Exemption, Bengaluru [In Short ‘Cit(E)’] Vide Din & Order No. Itba/Exm/F/Exm45/2025- 16/1077247685(1) Dt. 20/06/2025 & 1077646854(1) Dt. 24/06/2025. Itat-Panaji Page 1 Of 9

trust established in accordance with applicable law & in operation as such [Constitution/Establishment] (b) whether all the entries of object clause are in consonance with the ‘charitable purpose’ as defined by section 2(15) of the Act [Objects] (c) whether there exist any implied or express provision in the constitutional & other administrative ITAT-Panaji Page 6 of 9 Fabrica Da Igreja

CONFRARIA DO SSMO SACRAMENTO E SANTOS REIS MAGOS DA IGREJA DE REISMAGOS,VEREM vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BANGALORE

Appeals are allowed for statistical purposes

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

trust established in accordance with applicable Indian Law & in operation as such [Constitution/Establishment] (b) whether all the entries of object clause are in consonance with the ‘charitable purpose’ as defined by section 2(15) of the Act [Objects] (c) whether there exist any implied or express provision in the constitutional & other administrative documents/policies etc., entitling any right or power

CONFRERIA DE N SRA DO BOM SUCCESSO DA CAPELA DE DONGORIM MANDUR,MANDURA vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BENGALURU

Appeals are allowed for statistical purposes

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

trust established in accordance with applicable Indian Law & in operation as such [Constitution/Establishment] (b) whether all the entries of object clause are in consonance with the ‘charitable purpose’ as defined by section 2(15) of the Act [Objects] (c) whether there exist any implied or express provision in the constitutional & other administrative documents/policies etc., entitling any right or power

CONFRARIA DE N SRA DO ROSARIO DA CAPELA DE NEURA,NEURA vs. COMMISSIONER OF INCOME TAX, (EXEMPTION), BENGALURU

Appeals are allowed for statistical purposes

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

trust established in accordance with applicable Indian Law & in operation as such [Constitution/Establishment] (b) whether all the entries of object clause are in consonance with the ‘charitable purpose’ as defined by section 2(15) of the Act [Objects] (c) whether there exist any implied or express provision in the constitutional & other administrative documents/policies etc., entitling any right or power

CONFRARIA DO SSMO SACRAMENTO E N SRA DE AMPARO DA IGREJA DE MANDUR,MANDUR vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BENGALURU

Appeals are allowed for statistical purposes

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

trust established in accordance with applicable Indian Law & in operation as such [Constitution/Establishment] (b) whether all the entries of object clause are in consonance with the ‘charitable purpose’ as defined by section 2(15) of the Act [Objects] (c) whether there exist any implied or express provision in the constitutional & other administrative documents/policies etc., entitling any right or power

COFRE DA CAPELA DE S SEBASTIAO NEURA,NEURA vs. COMMISSIONER OF INCOME TAX, (EXEMPTION), BENGALURU

Appeals are allowed for statistical purposes

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

trust established in accordance with applicable Indian Law & in operation as such [Constitution/Establishment] (b) whether all the entries of object clause are in consonance with the ‘charitable purpose’ as defined by section 2(15) of the Act [Objects] (c) whether there exist any implied or express provision in the constitutional & other administrative documents/policies etc., entitling any right or power

SRI SAI SWADHYAY MANDAL,PORVORIM, GOA vs. ITO (EXEMPTION), WARD 1, PANAJI, PANAJI, GOA

Appeals are allowed for statistical purposes in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 001/Pan/2025 Shree Sadguru Educational & Welfare Trust Gurukul, Chogam Road, Bela Vista Wadda, Sangolda, North Goa, Goa-403521. Pan : Aaets8722K . . . . . . . Appellant(1) & Ita Nos. 005/Pan/2025 Sri Sai Swadhyay Mandal 47, ‘Saidham’ Defence Colony, Alto-Porvorim, Bardez, Goa-403521. Pan : Aabts2136E . . . . . . . Appellant(2) V/S Income Tax Officer, Exemption, Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr S V Padhye [‘Ld. Ar’] Revenue By : Mr Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 03/03/2025 Date Of Pronouncement : 11/03/2025 Order Per G. D. Padmahshali; These Twin Appeals Of Captioned Assessee’S Are Instituted U/S 251(1)(C) Of The Income-Tax Act, 1961 [Hereinafter ‘The Act’] Against Respective Order Of The Ld. Commissioner Of Income Tax (Exemption), Bangalore [Hereinafter ‘Ld. Cit(E)’] Passed U/S 80G(5) Of The Act Whereby Applications For Grant Of Regular 80G Approval/Recognition Were Rejected In Limine.

3. Succinctly stated facts borne out of case records are that; 3.1 the assessee is established as a Public Charitable Trust on 22/10/2004 and was initially registered under the Act vide Regn. No S-186/12A/CIT/PNJ/2004-2005. Pursuant to new scheme/provisions of mandatory revalidation of Charitable Institutions brought in by Finance Act, 2020 the assessee applied a fresh for grant

SHREE SADGURUS EDUCATIONAL & WELFARE TRUST,ALTO PORVORIM vs. ITO (EXEMPTIONS) , WARD 1, PANAJI

Appeals are allowed for statistical purposes in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 001/Pan/2025 Shree Sadguru Educational & Welfare Trust Gurukul, Chogam Road, Bela Vista Wadda, Sangolda, North Goa, Goa-403521. Pan : Aaets8722K . . . . . . . Appellant(1) & Ita Nos. 005/Pan/2025 Sri Sai Swadhyay Mandal 47, ‘Saidham’ Defence Colony, Alto-Porvorim, Bardez, Goa-403521. Pan : Aabts2136E . . . . . . . Appellant(2) V/S Income Tax Officer, Exemption, Panaji, Goa. . . . . . . . Respondent Appearances Assessee By : Mr S V Padhye [‘Ld. Ar’] Revenue By : Mr Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 03/03/2025 Date Of Pronouncement : 11/03/2025 Order Per G. D. Padmahshali; These Twin Appeals Of Captioned Assessee’S Are Instituted U/S 251(1)(C) Of The Income-Tax Act, 1961 [Hereinafter ‘The Act’] Against Respective Order Of The Ld. Commissioner Of Income Tax (Exemption), Bangalore [Hereinafter ‘Ld. Cit(E)’] Passed U/S 80G(5) Of The Act Whereby Applications For Grant Of Regular 80G Approval/Recognition Were Rejected In Limine.

3. Succinctly stated facts borne out of case records are that; 3.1 the assessee is established as a Public Charitable Trust on 22/10/2004 and was initially registered under the Act vide Regn. No S-186/12A/CIT/PNJ/2004-2005. Pursuant to new scheme/provisions of mandatory revalidation of Charitable Institutions brought in by Finance Act, 2020 the assessee applied a fresh for grant

M/S HEALTHWAY CHARITABLE TRUST,PANAJI vs. COMMISSIONER OF INCOME TAX, EXEMPTION, BENGALURU

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri S. S. Godara & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.259/Pan/2019 M/S. Healthway Charitable Vs. Cit, Exemption, Trust, Bengaluru. Healthway Hospital Near Peoples High School, Fontainhas, Mala, Panaji, Goa- 403001. Pan : Aabth3867P Appellant Respondent Assessee By : None Revenue By : Shri N. Shrikanth Date Of Hearing : 14.07.2023 Date Of Pronouncement : 18.07.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Rejection Of Approval U/S 80G(5)(Vi) Of The Income Tax Act, 1961 (‘The Act’) By The Ld. Ld. Commissioner Of Income Tax (Exemptions), Bangalore [‘The Cit (Exemptions)’] Vide Order Dated 24.06.2019. 2. Briefly, The Facts Of The Case Are That The Appellant Is A Trust Registered Under The Provisions Of Section 12Aa Of The Act On 30.11.2015 Vide Order No. Cit(E)Blr/12A/Pnj-

Charitable Vs. CIT, Exemption, Trust, Bengaluru. Healthway Hospital Near Peoples High School, Fontainhas, Mala, Panaji, Goa- 403001. PAN : AABTH3867P Appellant Respondent Assessee by : None Revenue by : Shri N. Shrikanth Date of hearing : 14.07.2023 Date of pronouncement : 18.07.2023 आदेश / ORDER PER INTURI RAMA RAO, AM: This is an appeal filed by the assessee directed against the rejection of approval

SHRI MAHARUDRA HANUMAN NYASA,PORVORIM vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BANGALORE

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

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.346/Pan/2025 Shri.Maharudra Hanuman Vs Cit (Exemptions), Nyasa, Unity Buildingannexe, . M 60, Housing Board Colony, Mission Read, Alto Porvorim, Bengaluru-560027, Bardez, North Goa-403521, Karnataka. Goa. Pan .No. Aagts6084E (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Prashanth Jain.Ar Revenue By Shri.Satish.M.Cit-Dr

trust and is undertaking charitable activities. The assesse was granted provisional registration under section 12AB of the Act in Form.no.10AC on 12-03-2022. Subsequently, as Shri.Maharudra Hanuman Nyas. per the amended, provisions of section 12AB of the Act, The assessee for the purpose of permanent registration has uploaded e-application in Form. No.10AB

SHRI RAMPURUSH MANDIR SOCIETY,CUNCOLIM vs. ASSISTANT DIRECTOR, CPC, BANGALORE

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 75 & 76/Pan/2025 Assessment Year : 2021-22 & 2022-23 Shri Rampurush Mandir Society Veroda, Cuncolim, Salcete, Goa-403703. Pan : Aadas9268E . . . . . . . Appellant V/S Asstt. Director Of Income Tax, Cpc, Bengaluru. . . . . . . . Respondent Appearances Assessee By : Mr Narcinva Lotlikar [‘Ld. Ar’] Revenue By : Mr Ish Gupta [‘Ld. Dr’] Date Of Conclusive Hearing : 25/08/2025 Date Of Pronouncement : 26/08/2025 Order Per G. D. Padmahshali; The Twin Appeals Of The Appellant Assessee Impugns Separate Din & Orders Both Dt. 10/03/2025 Passed By The Addl./Jt. Commissioner Of Income Tax, Appeals(2), Kolkata [‘Ld. Cit(A)/Nfac’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Emanated Out Of Respective Summary Assessment Dt. 23/09/2022 & 16/03/2023 Passed U/S 143(1) Of The Act By The National Faceless E-Asstt Centre [‘Ld. Ao’ Hereinafter] Anent To Assessment Years 2021- 22 & 2022-23 [‘Ays’ Hereinafter].

Charitable Trust Vs ITO’ [2018, 98 taxmann.com 474 (Bang)] the Ld. Co-ordinate bench while dealing with a similar matter where trust was not registered u/s 12/12A of the Act and was filing its return as ITAT-Panaji Page 16 of 18 Shri Rampurush Mandir Society Vs CPC ITA Nos.75 & 76/PAN/2025 AY: 2021-22 & 2022-23 AOP, therefore was held