DIKSHA EDUCATIONAL RESEARCH FOUNDATION,PATNA vs. CIT, EXEMPTION, PATNA, PATNA

Appeals are allowed on the basis of finding given in the lead case (ITA No

Bench: SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Charitable Trust HR Digha Shivallya Charitable Trust Sagyan Educational Research Charitable Trust assessee trusts

SAGYAN EDUCATIONAL RESEARCH CHARITABLE TRUST,GOPALGANJ vs. CIT (EXEMPTION), PATNA

Appeals are allowed on the basis of finding given in the lead case (ITA No

Bench: SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Charitable Trust HR Digha Shivallya Charitable Trust Sagyan Educational Research Charitable Trust assessee trusts

AKSHAY EDUCATIONAL & SOCIAL WELFARE CHARITABLE TRUST,BODHGAYA vs. DCIT, CIRCLE-3, GAYA

In the result, the appeal of the assessee is hereby dismissed

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. No.03/Pat/2017 Assessment Year: 2011-12 Akshay Educational & Social Welfare Charitable Trust............……….……Appellant Amawa (Thakar), Bodhgaya-824234. [Pan:Aacta5613R] Vs. Dcit, Circle-3, Gaya….....………............…............……........……...…..…..Respondent Appearances By: Shri A.K. Rastogi, Sr. Adv. & Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 21, 2022 Date Of Pronouncing The Order : January 11, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.08.2016 Of The Commissioner Of Income Tax (Appeals)-1, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:

trust has been established for charitable purposes. The main aim and objectives of the trust is to help

JEEVAN DEEP CHARITABLE TRUST,MADHUBANI vs. ITO (EXEMPTION) WARD, MUZAFFARPUR, MUZAFFARPUR

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

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

Charitable Trust. 1.1. The brief facts of the case of the appellant are that the assessee is a charitable

HARDEO DASS NATMULL BAIROLIYA CHARITY TRUST,DARBHANGA vs. THE PRINCIPAL CIT(EXEMPTION)PATNA, PATNA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

charitable activity where as in this case trust had already commenced the charitable activity on 17.4.20 by making

HARDEO DASS NATMULL BAIROLIYA CHARITY TRUST,DARBHANGA vs. THE PRINCIPAL CIT(EXEMPTION), PATNA

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

charitable activity where as in this case trust had already commenced the charitable activity on 17.4.20 by making

ITO, WARD-1(EXEMPTION), PATNA vs. AISHWARYA FOUNDATION, PATNA

In the result, the appeal is allowed

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 103/Pat/2020 Assessment Year: 2014-15 Income Tax Officer, Ward-1, Aishwarya Foundation, Patna Exemption Vs 46, Patliputra Colony Near Sahyog Hospital Patliputra Colony Patna - 800013 [Pan: Aacta0834A] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Soumitra Choudhury, Advocate Revenue By : Shri Rupesh Agrawal, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 13/04/2023 घोषणा क" तारीख /Date Of Pronouncement: 03/05/2023 आदेश/O R D E R Per Sonjoy Sarma: The Present Appeal Is Directed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) - 1, Patna, (Hereinafter The “Ld. Cit(A)”) Dt. 10/09/2020, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2014-15. 2. The Sole Issue Raised By The Department Before Us In The Instant Lis Relates To The Deletion Of Addition Of Rs.2,61,72,000/- By The Ld. Cit(A) Made By The Assessing Officer In The Assessment Framed U/S 143(3) Of The Act On 30/12/2016 On Account Of Alleged Anonymous Donations Made U/S 115Bbc Of The Act. 3. Brief Facts Of The Case Are That The Assessee Trust Is A Charitable Organization Registered U/S 12Aa Of Act. It Filed Its Return Of Income For The Year Under Consideration On 24/06/2015 Declaring Total Income At ‘Nil’. Case Of Assessee Was Selected For Scrutiny Through Cass Followed By Issuance Of Notice U/S 143(2) & 142(1) Of The Act. During The Course Of Assessment Proceedings, The Assessing Officer Noted From The Income & Expenditure Account That The Assessee Had Shown Income At Rs.2,61,72,000/- Which Was Received As Donation & Incurred Expenses To The Tune Of Rs.2,22,47,910/- Which Resulted In Income Over Expenditure At

charitable or religious trusts or institutions as well as partly charitable or religious trusts or institutions

NARAYANI EDUCATIONAL HEALTH AND CHARITABLE TRUST,PATNA vs. DCIT, CENTRAL CIRCLE-2, PATNA

Appeals of the assessee are allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.301 To 303/Pat/2023 Assessment Years: 2013-14, 2015-16 & 2016-17 Narayani Educational Health & Charitable Trust……..………….……Appellant A/78, P. C Colony, Kankarbagh, Patna, Bihar-800020. [Pan: Aactn2955K] Vs. Dcit, Central Circle-2, Patna....….….. ……………….........……...…..…..Respondent Appearances By: Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2025 Date Of Pronouncing The Order : February 07, 2025 Order Per Sonjoy Sarma: The Captioned Appeals Have Been Preferred By The Assessee Against Separate Orders All Dated 28.04.2023 Passed By The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2013-14, 2015-16 & 2016-17 Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, The Registry Has Informed That There Are Delays Of 106 Days In Filing All The Present Appeals. The Assessee Filed Applications For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Applications, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delays Were Not Intentional. We, Therefore

Charitable Trust Copy of the order forwarded to: 1. Narayani Educational Health And Charitable Trust 2. DCIT

NARAYANI EDUCATIONAL HEALTH AND CHARITABLE TRUST,PATNA vs. DCIT,CENTRAL CIRCLE-2, PATNA

Appeals of the assessee are allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.301 To 303/Pat/2023 Assessment Years: 2013-14, 2015-16 & 2016-17 Narayani Educational Health & Charitable Trust……..………….……Appellant A/78, P. C Colony, Kankarbagh, Patna, Bihar-800020. [Pan: Aactn2955K] Vs. Dcit, Central Circle-2, Patna....….….. ……………….........……...…..…..Respondent Appearances By: Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2025 Date Of Pronouncing The Order : February 07, 2025 Order Per Sonjoy Sarma: The Captioned Appeals Have Been Preferred By The Assessee Against Separate Orders All Dated 28.04.2023 Passed By The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2013-14, 2015-16 & 2016-17 Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, The Registry Has Informed That There Are Delays Of 106 Days In Filing All The Present Appeals. The Assessee Filed Applications For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Applications, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delays Were Not Intentional. We, Therefore

Charitable Trust Copy of the order forwarded to: 1. Narayani Educational Health And Charitable Trust 2. DCIT

NARAYANI EDUCATIONAL HEALTH AND CHARITABLE TRUST,PATNA vs. DCIT, CENTRAL CIRCLE-2, PATNA

Appeals of the assessee are allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.301 To 303/Pat/2023 Assessment Years: 2013-14, 2015-16 & 2016-17 Narayani Educational Health & Charitable Trust……..………….……Appellant A/78, P. C Colony, Kankarbagh, Patna, Bihar-800020. [Pan: Aactn2955K] Vs. Dcit, Central Circle-2, Patna....….….. ……………….........……...…..…..Respondent Appearances By: Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2025 Date Of Pronouncing The Order : February 07, 2025 Order Per Sonjoy Sarma: The Captioned Appeals Have Been Preferred By The Assessee Against Separate Orders All Dated 28.04.2023 Passed By The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2013-14, 2015-16 & 2016-17 Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, The Registry Has Informed That There Are Delays Of 106 Days In Filing All The Present Appeals. The Assessee Filed Applications For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Applications, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delays Were Not Intentional. We, Therefore

Charitable Trust Copy of the order forwarded to: 1. Narayani Educational Health And Charitable Trust 2. DCIT

FARIDI FOUNDATION,ARRAH vs. CIT (EXEMPTION), PATNA

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

charitable purposes though\nthe deed of the trust shows that the trust has been created for religious

GURUDWARA BAL LEELA MANINI SANGAL TRUST,PATNA vs. DCIT, CPC, BANGALORE

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 10/Pat/2022 Assessment Year: 2014-15 Gurudwara Bal Leela Manini Sangat Trust National Faceless Appeal Patna Sahib Vs Centre, Delhi Patna City Patna - 800008 [Pan: Aabtg9954E] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri D.V. Pathy, Advocate & Shri Hiresh Karana, Advocate Revenue By : Md. A.H. Chowdhary, Cit D/R सुनवाई क" तारीख/Date Of Hearing : 05/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/03/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The National Faceless Appeal Centre (Hereinafter The “Ld. Cit(A)”) Dt. 29/12/2021, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2014-15. 2. Though The Assessee Has Raised Eight Grounds Of Appeal But The Grievance Are Two Fold:- (I) The Ld. Cit(A) Erred In Dismissing The Appeal In Limine For Delay Of 1423 Days In Filing Of The Appeal Ignoring The Fact That The Delay Occurred Due To Fault Of The Counsel, Who Had Bona Fide Belief That The Impugned Order Is Rectifiable.

charitable trust engaged in carrying out the charitable activities. Though, for the 4 I.T.A. No. 10/Pat/2022 Assessment

MAHARAJADHIRAJA KAMESHWAR SINGH CHARITABLE TRUST,DARBHANGA vs. ITO EXEMPTION WARD, MUZAFFARPUR

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

Bench: The Ld. Cit(A) In Protest Against The Action Of The Ld. Ao, Cpc, Bengaluru. The Ld. Ao, Cpc Has Denied Exemption U/S 11 Of The Act Since Apparently The Return Was Filed Belatedly U/S 139(4) Of The Act. Before The Ld. Cit(A), It Is Recorded In Para 6.2 That Two Opportunities Given For Presenting The Facts

Charitable Trust, Kameshwar Nagar, Lalbagh, Darbhanga - 846004 .....................…...…………….... Appellant [PAN: AADTM3390E] vs. ITO (Exemption), Ward, Muzaffarpur – 842001 (Bihar) ...............…..…...................... Respondent

NARAYANI EDUCATIONAL HEALTH AND CHARITABLE TRUST ,PATNA vs. DCIT,CENTRAL CIRCLE-2, PATNA , PATNA

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

Charitable Trust Central Revenue Building, 6 th A/78, P.C. Colony, Kankarbagh, floor, Annex to Bir Chand Patel, Vs. Patna

NARAYANI EDUCATIONAL HEALTH AND CHARITABLE TRUST ,PATNA vs. DCIT, CENTRAL CIRCLE-2,PATNA , PATNA

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

Charitable Trust Central Revenue Building, 6 th A/78, P.C. Colony, Kankarbagh, floor, Annex to Bir Chand Patel, Vs. Patna

NARAYANI EDUCATIONAL HEALTH AND CHARITABLE TRUST,PATNA vs. DCIT, CENTRAL CIRCLE-2, PATNA

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

Charitable Trust Central Revenue Building, 6 th A/78, P.C. Colony, Kankarbagh, floor, Annex to Bir Chand Patel, Vs. Patna

SAHU MAHABIR TRUST,DARBHANGA vs. CIT (E) PATNA, CIT (E) PATNA

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleassessment Year: 2021-22 To 2023-24 Sahu Mahabir Trust, Darbhanga Cit(E), Patna Vs. Pan: Aavts 8482 M (Appellant) (Respondent) Present For: Appellant By : Shri P.P. Singh, Ar Respondent By : Shri Sushil Kumar Mishra, Jcit, Dr Date Of Hearing : 07.03.2024 Date Of Pronouncement : 15.03.2024 O R D E R Per Sonjoy Sarma, Jm: This Appeal Of The Assessee For The Assessment Year 2013-14 Is Directed Against The Order Dated 12.10.2023 Passed By The Ld. Commissioner Of Income-Tax (Exemption), Patna [Hereinafter Referred To As ‘The Ld. Cit(A)’].

charitable trust doing charitable activity running eye hospital in the name of Mahavir Netrayalya for treatment of poor

SUNITI CHATURBHUJ SOCIAL FOUNDATION,,HAJIPUR vs. CIT(EXEMPTION), PATNA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 620/Pat/2024 Assessment Year: 2024-2025 Suniti Chaturbhuj Social Foundation,....……Appellant C/O. Gyanendra Priyadarshi, Andarkila, Hajipur, Vaishali-844101, Bihar [Pan:Abhcs4841E] -Vs.- Commissioner Of Income Tax (Exemption),.Respondent Patna, 2Nd Floor, C.R. Building, Birchand Patel Path, Patna-800001, Bihar Appearances By: Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Assessee Rinku Singh, Cit, D.R., Appeared On Behalf Of The Revenue

Charitable Trust and engaged in various charitable activities. Notices were issued in respect of proceedings under section