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)

D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER 1. This is a batch of four appeals having inter connected issues and hence they are disposed of through a single order. 1.1 The present appeals arise from the orders passed by the Ld. Commissioner of Income Tax (Exemption), Patna [hereafter the Ld. CIT(E)]” through separate orders, all dated

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)

D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER 1. This is a batch of four appeals having inter connected issues and hence they are disposed of through a single order. 1.1 The present appeals arise from the orders passed by the Ld. Commissioner of Income Tax (Exemption), Patna [hereafter the Ld. CIT(E)]” through separate orders, all dated

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)

D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER 1. This is a batch of four appeals having inter connected issues and hence they are disposed of through a single order. 1.1 The present appeals arise from the orders passed by the Ld. Commissioner of Income Tax (Exemption), Patna [hereafter the Ld. CIT(E)]” through separate orders, all dated

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)

D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER 1. This is a batch of four appeals having inter connected issues and hence they are disposed of through a single order. 1.1 The present appeals arise from the orders passed by the Ld. Commissioner of Income Tax (Exemption), Patna [hereafter the Ld. CIT(E)]” through separate orders, all dated

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

D E R PER SONJOY SARMA, JUDICIAL MEMBER: 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

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

Appeal is treated as allowed for statistical purposes

Charitable Trust registered u/s. 12A of the Act as mentioned by the AO in the beginning of his assessment order. The case of the assessee was selected for complete scrutiny under CASS with a reason for non-filing of Audit Report in Form 10B/10BB. In response to the statutory notices issued by the AO, the assessee did not respond. Therefore

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)

D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. In the present three matters it is seen that there is a delay in filing of appeals which has been requested to be condoned by the Revenue. For the sake of convenience, the application for condonation of delay for AY 2013- 14 is extracted as under: “With reference to the subject

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)

D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. In the present three matters it is seen that there is a delay in filing of appeals which has been requested to be condoned by the Revenue. For the sake of convenience, the application for condonation of delay for AY 2013- 14 is extracted as under: “With reference to the subject

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)

D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. In the present three matters it is seen that there is a delay in filing of appeals which has been requested to be condoned by the Revenue. For the sake of convenience, the application for condonation of delay for AY 2013- 14 is extracted as under: “With reference to the subject

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

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

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

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

d) As the election in the state is going on, the signing authority of the Appellant is preoccupied & out of town owing to his duty & responsibility. e) All these have caused delay in filing the appeal in time. The following are the details: Particulars Date Delay Order received through portal 02.03.2024 Due date of filing appeal 04.05.2024 The Appellant took

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

D E R Per Rajpal Yadav, Vice-President (KZ):- The assessee is in appeal before the Tribunal against the order of ld. Commissioner of Income Tax (Appeals), Patna-3 dated 31st December, 2021 passed for A.Y. 2012- 13. 2. The assessee has challenged reopening of assessment by issuance of a notice under section 148 of the Income

SHRI NARNAULIYE AGRAWAL SEWA SAMITI,SHERGHATI GAYA vs. CIT EXEMPTION, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

D S Mittle Charities VS, CIT Exemption ITA Nos. 6037& 6038/Mum/2024 on the same fact and circumstances, honourable ITAT Mumbai set aside the impugned order of the Id. CIT(E) and restore the matter back to Id. CIT(E). 2. The Ld. CIT(Exemption) erred in rejecting the appellants application u/s.12A (form 10AB) basically on non-furnishing of additional documents

SHRI NARNAULIYE AGRAWAL SEWA SAMITI,SHER GHATI GAYA vs. CIT EXEMPTION, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

D S Mittle Charities VS, CIT Exemption ITA Nos. 6037& 6038/Mum/2024 on the same fact and circumstances, honourable ITAT Mumbai set aside the impugned order of the Id. CIT(E) and restore the matter back to Id. CIT(E). 2. The Ld. CIT(Exemption) erred in rejecting the appellants application u/s.12A (form 10AB) basically on non-furnishing of additional documents

ALMAHAD TRUST ,PATNA vs. ITO EXEMPTION, WARD-1, PATNA , PATNA

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

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

D E R PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER This is an appeal filed by the assessee against the order passed u/s 250 of the Income Tax Act, 1961 (hereafter “the Act”) by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereafter “the Ld. CIT(A)] dated 19.08.2024, DIN & order No. ITBA/NFAC/S/250/2024-25/1067740098(1

AMS EDUCATIONAL AND WELFARE FOUNDATION,KISHANGANJ vs. CIT(EXEMPTION), PATNA

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

Bench: Shri A.T. Varkey & Shri Girish Agrawal

D E R Per Girish Agrawal, Accountant Member: Both the appeals by the assessee are arising out of different orders passed by Ld. CIT(Exemption), Patna vide Order No. ITBA/EXM/S/EXM-1/2018-19/1012780653(1) and Memo No. CIT (E)/Pat/12AA & 80G/Reg/04(23)2018-19/4525-29 both dated 03.10.2018 u/s 12AA and 80G(5)(vi) of the Income-tax Act, 1961 (hereinafter referred