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)

charitable or religious purposes within the meaning of section 11 read with section 2(15) of the IT Act 1961. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause (ac) of sub-section (1) of section 12A is rejected. 6. Under the circumstances mentioned above, the provisional registration granted

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)

charitable or religious purposes within the meaning of section 11 read with section 2(15) of the IT Act 1961. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause (ac) of sub-section (1) of section 12A is rejected. 6. Under the circumstances mentioned above, the provisional registration granted

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 or religious purposes within the meaning of section 11 read with section 2(15) of the IT Act 1961. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause (ac) of sub-section (1) of section 12A is rejected. 6. Under the circumstances mentioned above, the provisional registration granted

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 or religious purposes within the meaning of section 11 read with section 2(15) of the IT Act 1961. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause (ac) of sub-section (1) of section 12A is rejected. 6. Under the circumstances mentioned above, the provisional registration granted

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

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

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

1)\nii) Donation Boxes\na) The Trust has installed donation boxes at various shops, Masjids, Homes\nacross city. Any person visiting to any of these places can easily donate any\namount of his will for the purpose of religious and charitable activity being\ncarried out by the Trust.\nb) Premise owners are responsible to look after the boxes installed

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

1 provides that where the total income of an assessee being a person in receipt of income on behalf of any trust or institution referred to in section 11 includes income by way of anonymous donation, the income tax is payable by it on this amount as prescribed in the section. Sub-section 3 defines the expression anonymous donation

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

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

Appeal is treated as allowed for statistical purposes

1). Hence, exemption under section 11 and 12 is also not applicable and the exemption claimed of Rs. 5,80,39,300/-plus other section in ITR is hereby disallowed by the undersigned. After due consideration of facts & circumstances and verification of documents available in this office, the income of the assessee AOP/BOI is computed u/s 144 i.e. Best Judgment

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

1,79,64,179/- by invoking ITA No.: 14/PAT/2018 Assessment Year: 2014-15 Society for Advancement of Village Economy. proviso to section 2(15) of the Act denying of exemption u/s 11 of the Act. Both the lower authorities erred in not appreciating submissions that the appellant trust being registered u/s 12AA of the Act as a public charitable

DCIT(EXEMPTION) CIRCLE, PATNA vs. M/S DEO MANGAL MEMORIAL TRUST, PATNA

In the result, these appeals filed by the Revenue are allowed for statistical purposes

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

11(1) of the Act was to be allowed to the assessee-trust. (c) Basis for disallowing expenses has not found favour with the Ld. CIT(A) and accordingly the action of Ld. AO was held as untenable. Broady on the basis of these findings none of the actions of Ld. AO found support with

DCIT(EXEMPTION) CIRCLE, PATNA vs. M/S DEO MANGAL MEMORIAL TRUST, PATNA

In the result, these appeals filed by the Revenue are allowed for statistical purposes

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

11(1) of the Act was to be allowed to the assessee-trust. (c) Basis for disallowing expenses has not found favour with the Ld. CIT(A) and accordingly the action of Ld. AO was held as untenable. Broady on the basis of these findings none of the actions of Ld. AO found support with

DCIT(EXEMPTION) CIRCLE, PATNA vs. M/S DEO MANGAL MEMORIAL TRUST, PATNA

In the result, these appeals filed by the Revenue are allowed for statistical purposes

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

11(1) of the Act was to be allowed to the assessee-trust. (c) Basis for disallowing expenses has not found favour with the Ld. CIT(A) and accordingly the action of Ld. AO was held as untenable. Broady on the basis of these findings none of the actions of Ld. AO found support with

KARAM AGRAMI AMAN AUR MAITRI SANSTAN,RANCHI vs. CIT(EXEMPTION), PATNA, PATNA

Appeal is allowed for statistical purposes

Bench: Hon’Ble Income Tax Appellate Tribunal, Patna Against The Order Of The Ld. Commissioner Of Income Tax (Exemptions), Patna For Rejection Of Registration Under Section 12Ab(1)(B)(Iii) Of The Income Tax Act, 1961. 2. The Said Order Of The Ld. Commissioner Of Income Tax (Exemptions), Patna Was Passed & Received On The Same Date By Mail. Therefore, The Appeal Should Have Been Instituted Within 60 Days From Receipt Of Such Order I.E., On Or Before 04.05.2024. I.T.A. No. 505/Pat/2024 Karam Agrami Aman Aur Maitri Sanstan

Trust wholly for charitable or religious purposes within the meaning of section 11 read with section 2(15) of the IT Act 1961 Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause (ac) of subsection (1

ST JOHNS EDUCATION TRUST,PATNA vs. INCOME TAX OFFICER, EXEMPTION WARD, PATNA

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

Bench: Shri George Mathan & Shri Rakesh Mishra

charitable or religious purposes within the meaning of section 11 read I.T.A. No.: 670/PAT/2024 Assessment Year: 2024-25 St. Johns Education Trust St. Johns Society for Education. with section 2(15) of the IT Act 1961 and failed to prove the compliance of other laws. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause

ST JOHNS SOCIETY FOR EDUCATION,HAJIPUR vs. INCOME TAX OFFICER, EXEMPTION WARD, PATNA

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

Bench: Shri George Mathan & Shri Rakesh Mishra

charitable or religious purposes within the meaning of section 11 read I.T.A. No.: 670/PAT/2024 Assessment Year: 2024-25 St. Johns Education Trust St. Johns Society for Education. with section 2(15) of the IT Act 1961 and failed to prove the compliance of other laws. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause

DOLLY GHOSH,BHAGALPUR vs. ACIT CENTRAL CIRCLE 1 PATNA, PATNA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

charitable or religious purposes or by an institution established wholly or partly for such purposes or by an association or institution referred to in clause (21) or clause (23), or by a fund or trust or institution referred to in sub-clause (iv) or sub-clause (v) or by any university or other educational institution referred to in sub-clause

GD MOTHER EDUCATIONAL SOCIETY ,MUZAFFARPUR vs. ACIT 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

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