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)

2 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 Trust I.T.A. No. 597/PAT/2024 Sagyan Educational Research Charitable Trust, Hathwa Mansion, Mirganj, Gopalganj (Bihar) - 800001 [PAN: AAGTS8264A] ……..…...…………….... Appellant vs. CIT (Exemption), Patna ................................. Respondent Appearances by: Assessee represented by : Akkal Dudhwewala, FCA Vidhi Ladia, ACA Department

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)

2 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 Trust I.T.A. No. 597/PAT/2024 Sagyan Educational Research Charitable Trust, Hathwa Mansion, Mirganj, Gopalganj (Bihar) - 800001 [PAN: AAGTS8264A] ……..…...…………….... Appellant vs. CIT (Exemption), Patna ................................. Respondent Appearances by: Assessee represented by : Akkal Dudhwewala, FCA Vidhi Ladia, ACA Department

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)

2 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 Trust I.T.A. No. 597/PAT/2024 Sagyan Educational Research Charitable Trust, Hathwa Mansion, Mirganj, Gopalganj (Bihar) - 800001 [PAN: AAGTS8264A] ……..…...…………….... Appellant vs. CIT (Exemption), Patna ................................. Respondent Appearances by: Assessee represented by : Akkal Dudhwewala, FCA Vidhi Ladia, ACA Department

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)

2 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 Trust I.T.A. No. 597/PAT/2024 Sagyan Educational Research Charitable Trust, Hathwa Mansion, Mirganj, Gopalganj (Bihar) - 800001 [PAN: AAGTS8264A] ……..…...…………….... Appellant vs. CIT (Exemption), Patna ................................. Respondent Appearances by: Assessee represented by : Akkal Dudhwewala, FCA Vidhi Ladia, ACA Department

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

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

12A cannot be denied\non this ground. It is submitted that section 115BBC of the Income Tax\nAct, 1961 provides clarity that a religious trust may not be able to keep\na record of identity of the people providing anonymous donation. Hence\nsub-section (2) of section 115BBC explicitly excludes the religious trust\nas well as religious and 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)

2. For that Ld CIT Exemption erred in holding that maiden transaction of donation to Chief minister relief fund can not be considered as carrying of charitable activities in accordance with the object of trust. 3. For that Ld CIT exemption failed to appreciate the provision of section 12A

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)

2. For that Ld CIT Exemption erred in holding that maiden transaction of donation to Chief minister relief fund can not be considered as carrying of charitable activities in accordance with the object of trust. 3. For that Ld CIT exemption failed to appreciate the provision of section 12A

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\nor religious purpose in accordance with the Act. Further, Section\n164(2) provides that in case exemption is denied under section 11,\nsuch income of the trust shall be charged to tax at maximum marginal\nrate. For the Trusts and Institutions registered under section 12A

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

Appeal is treated as allowed for statistical purposes

12A(1)(b) is as under: "If total income of the trust or insinuation as computed under this act without giving effect to the provisions of section 11 and section 12 exceeds [the maximum amount (i.e. Rs.2.50 thousand) which is not chargeable to Income tax) in any previous year, the accounts of the trust or institution for that year have

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

charitable or religious objectives as required under the provisions of the Act. The application filed on Form No. 10AB seeking the regular registration under the provision of sub-clause (iii) of clause (ac) of sub-section (1) of section 12A read with section 12AB(1)(b) of the Act was rejected and the provisional registration granted u/s ITA No.: 519/PAT/2025

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

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

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

2 For that the appellant trust has claimed exemption u/s 12A and all the necessary forms and audit report were filed within the due date. The ITR was also filed within the extended due date u/s 139(1). In such a case claim for exemption should not have been disallowed. 3 For that the learned CIT(A) should not have

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.

2. That an order/intimation under Section 143 (1) of the Income Tax Act, 1961 for the Assessment Year 2014 - 15 was passed by the CPC Bangalore on 10.03.2016. 3. That in the said order the income was computed on the voluntary contribution and income from other sources earned by the trust. Thus, the gross receipts itself was subjected

GURUDWARA BAL LEELA MAINI SANGAT TRUST,PATNA vs. DC/AC, EXEMPTION, PATNA

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

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

charitable trust registered u/s 12A of the Act through an order dated 27.12.2019. The Ld. AO made the following two additions: (i) depreciation Rs. – 61,27,941/- I.T.A. No. 299/Pat/2024 Gurudwara Bal Leela Maini Sangat Trust (ii) Cash deposited in bank Rs. – 49,88,100/-. 1.2. It is seen that the addition on account of depreciation has been made

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) of section 12A

DAWAT E ISLAMI HIND,JAMSHDPUR vs. CIT-EXEMPTION, PATNA

The appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumar

12A(a). This application of the assessee has been rejected by the ld. Commissioner. On perusal of the order suggests that ld. Commissioner treated the assessee-Trust as a Charitable Trust, whereas the case of the assessee is that it is a Religious Trust and its case ought to have been examined by keeping in mind its object

SARVODAYA SAMAJ KALYAN SANSTHAN,JAMUI vs. CPC , BANGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

charitable purpose within the meaning of section 2(15) of the Income Tax Act. The aggregate annual receipts from fee of students were Rs.18,18,863/- and after expending Rs.15,76,363/- on maintenance and salary of staff, there was a surplus of Rs.2,42,499/-, which was treated as income, even though the assessee is exempt from income