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)

1)(ac)(vi) in Form 10AC was also cancelled. In this regard, we may take ITA No. 594/Pat/2024 as the lead case and the finding of Ld. CIT(E) there may be extracted for reference: 3 ITA Nos. 594-597/PAT/2024 Diksha Educational Research Foundation Diksha Educational Research Foundation Charitable Trust HR Digha Shivallya Charitable Trust Sagyan Educational Research Charitable

DIKSHA EDUCATIONAL RESEARCH FOUNDATION CHARITABLE TRUST, PATNA,PATNA vs. CIT E, 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)

1)(ac)(vi) in Form 10AC was also cancelled. In this regard, we may take ITA No. 594/Pat/2024 as the lead case and the finding of Ld. CIT(E) there may be extracted for reference: 3 ITA Nos. 594-597/PAT/2024 Diksha Educational Research Foundation Diksha Educational Research Foundation Charitable Trust HR Digha Shivallya Charitable Trust Sagyan Educational Research Charitable

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)

1)(ac)(vi) in Form 10AC was also cancelled. In this regard, we may take ITA No. 594/Pat/2024 as the lead case and the finding of Ld. CIT(E) there may be extracted for reference: 3 ITA Nos. 594-597/PAT/2024 Diksha Educational Research Foundation Diksha Educational Research Foundation Charitable Trust HR Digha Shivallya Charitable Trust Sagyan Educational Research Charitable

HR DIGHA SHIVALLYA CHARITABLE TRUST,PATNA vs. CIT E, 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)

1)(ac)(vi) in Form 10AC was also cancelled. In this regard, we may take ITA No. 594/Pat/2024 as the lead case and the finding of Ld. CIT(E) there may be extracted for reference: 3 ITA Nos. 594-597/PAT/2024 Diksha Educational Research Foundation Diksha Educational Research Foundation Charitable Trust HR Digha Shivallya Charitable Trust Sagyan Educational Research Charitable

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

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

Trust wholly for religious and charitable\npurposes. In the result, the application filed in Form 10AB for grant of\nregular registration under sub clause (iii) of clause (ac) of sub-section (1

M/S SATYAM EDUCATIONAL HEALTH & CHARITABLE TRUST,PATNA vs. PR. CIT-CENTRAL, PATNA

In the result, all the four appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar]

Charitable Trust the assessment records came to the conclusion that the assessment orders passed by the AO u/s 143(3) read with Section 153A of the Act from AY 2013-14 to 2016-17 were erroneous in so far as prejudicial to the interest of the revenue as the AO has failed to take necessary action in examining the various

M/S SATYAM EDUCATIONAL HEALTH & CHARITABLE TRUST,PATNA vs. PR. CIT-CENTRAL, PATNA

In the result, all the four appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar]

Charitable Trust the assessment records came to the conclusion that the assessment orders passed by the AO u/s 143(3) read with Section 153A of the Act from AY 2013-14 to 2016-17 were erroneous in so far as prejudicial to the interest of the revenue as the AO has failed to take necessary action in examining the various

M/S SATYAM EDUCATIONAL HEALTH & CHARITABLE TRUST,PATNA vs. PR. CIT-CENTRAL, PATNA

In the result, all the four appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar]

Charitable Trust the assessment records came to the conclusion that the assessment orders passed by the AO u/s 143(3) read with Section 153A of the Act from AY 2013-14 to 2016-17 were erroneous in so far as prejudicial to the interest of the revenue as the AO has failed to take necessary action in examining the various

M/S SATYAM EDUCATIONAL HEALTH & CHARITABLE TRUST,PATNA vs. PR. CIT-CENTRAL, PATNA

In the result, all the four appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar]

Charitable Trust the assessment records came to the conclusion that the assessment orders passed by the AO u/s 143(3) read with Section 153A of the Act from AY 2013-14 to 2016-17 were erroneous in so far as prejudicial to the interest of the revenue as the AO has failed to take necessary action in examining the various

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

section (1) shall not apply to any anonymous donation received by— (a) any trust or institution created or established wholly for religious purposes; (b) any trust or institution created or established wholly for religious and charitable

OOSMANIA TRUST,MUZAFFARPUR vs. CIT (E), PATNA, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Trust formed on 27.07.1978 and had filed an application in Form No. 10AB on 15.02.2025 for grant of regular registration under sub-clause (iii) of clause (ac) of sub-section (1) of section 12A read with section 12AB(1)(b) of the Act. During the course of the proceedings initiated u/s 12AB of the Act and in order to verify

RAJBANSHI LOK KALYAN TRUST,SIWAN vs. CIT EXEMPTION, PATNA

In the result, the appeal of the assessee is allowed for statistical\npurposes

Trust.......\nAppellant\nJamapur, Ziradei, Siwan, Pin-841226.\nBihar..\n[PAN: AACTR6497G]\nvs.\nCIT (Exemption), Patna........\nRespondent\nAppearances by:\nShri Girjesh Tripathi, CA, appeared on behalf of the appellant.\nMd. Shadab Ahmed, DR, appeared on behalf of the Respondent.\nDate of concluding the hearing: October 14, 2025\nDate of pronouncing the order : October 22, 2025\nआदेश / ORDER\nPer Sonjoy Sarma, Judicial

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 activities in accordance with the object of trust. 3. For that Ld CIT exemption failed to appreciate the provision of section 12A(1

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 activities in accordance with the object of trust. 3. For that Ld CIT exemption failed to appreciate the provision of section 12A(1

ACIT, PATNA vs. NEW ERA SOCIAL DEVELOPMENT WELFARE SOCIETY, PATNA

Appeal is treated as allowed for statistical purposes

trust or institution for that year have been audited by an accountant as defined in the Explanation of sub section 2 of section 288 and the person in the receipt of the Income furnishes along with the return of income for the relevant assessment year the report of such audit in the prescribed form duly signed and verified by such

SHASHI KRISHNA EDUCATIONAL AVAM WELFARE SOCIETY,PATNA vs. AO, PATNA

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

charitable purposes, and therefore the conditions of section 11\nwere duly complied with.\n\n6. That the demand of Rs. 53,13,260/- is unjustified, arbitrary, and\ndeserves to be quashed.\n\n7. That the appellant craves leave to add, alter or withdraw any ground of\nappeal at the time of hearing.”\n\n3. Brief facts of the case

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.

Trust (ii) that the CPC erred in framing the order u/s 143(1) of the Act treating the gross receipts as income and not allowing the expenditure incurred in carrying out the charitable activities. 3. At the outset, the ld. Counsel for the assessee referring the first issue submitted that the delay in filing of the appeal before

SOCIETY FOR ADVANCEMENT OF VILLAGE ECONOMY,GAYA vs. ACIT(EXEMPTION) CIRCLE, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

charitable purpose and not any business or profession. 2. FOR THAT Ld. CIT(A) erred in law and on the facts in confirming action of AO assessing income of the appellant Trust at Rs 1,79,64,179/- by invoking ITA No.: 14/PAT/2018 Assessment Year: 2014-15 Society for Advancement of Village Economy. proviso to section

G D MOTHER EDUCATIONAL SOCIETY,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the four appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumari.T.A. Nos. 309, 310, 311 & 312/Pat/2023 Assessment Years: 2018-2019 To 2021-2022 G.D. Mother Educational Society,……………Appellant Akharaghat Road, Muzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Principal Commissioner Of Income Tax (Central), Patna,………………….……………………………….Respondent Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, C.A., Appeared On Behalf Of The Assessee Shri Ashok Kumar, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: October 25, 2024 Date Of Pronouncing The Order: November 20, 2024 O R D E R

Charitable Society -vs.- PCIT [2024] 166 taxmann.com 324 (Delhi-Trib.). The ld. A.R. also stated that the ld. Assessing Officer had himself invalidated the notices issued under section 148 of the Act dated 30.06.2021 for assessment years 2018-19, 2019-20 and 2020-21 by issuing fresh notices under section 148A(b) of the Act dated 25.05.2022 post the judgment