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 (PAN: AAHTS 1627 E) Appellant Respondent Date of Hearing (Virtual) 14 .02.2022 Date of Pronouncement 09.03.2022 For the Appellant Shri S.K. Tulsiyan, Advocate For the Respondent Shri Sanjay Mukherjee, CITDR ORDER Per Shri Rajesh Kumar, AM: All the four appeals filed by the assessee are directed against the orders passed u/s 263 of the Income

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 (PAN: AAHTS 1627 E) Appellant Respondent Date of Hearing (Virtual) 14 .02.2022 Date of Pronouncement 09.03.2022 For the Appellant Shri S.K. Tulsiyan, Advocate For the Respondent Shri Sanjay Mukherjee, CITDR ORDER Per Shri Rajesh Kumar, AM: All the four appeals filed by the assessee are directed against the orders passed u/s 263 of the Income

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 (PAN: AAHTS 1627 E) Appellant Respondent Date of Hearing (Virtual) 14 .02.2022 Date of Pronouncement 09.03.2022 For the Appellant Shri S.K. Tulsiyan, Advocate For the Respondent Shri Sanjay Mukherjee, CITDR ORDER Per Shri Rajesh Kumar, AM: All the four appeals filed by the assessee are directed against the orders passed u/s 263 of the Income

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 (PAN: AAHTS 1627 E) Appellant Respondent Date of Hearing (Virtual) 14 .02.2022 Date of Pronouncement 09.03.2022 For the Appellant Shri S.K. Tulsiyan, Advocate For the Respondent Shri Sanjay Mukherjee, CITDR ORDER Per Shri Rajesh Kumar, AM: All the four appeals filed by the assessee are directed against the orders passed u/s 263 of the Income

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

14 reported in 288 ITR (St.) 9 has explained these provisions which were introduced by the Finance Act, 2006 w.e.f. assessment year 2007- 08, which is as under: Income of wholly charitable or religious trusts or institutions as well as partly charitable or religious trusts or institutions is exempt from income-tax under sections

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

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

Trust along with necessary supporting documents and the Ld. CIT\n(Exemption) shall consider the same and thereafter decide the\napplication for final approval in accordance with law considering the\napplication of income for charitable purposes claimed by the assessee.\n10. In the result, the appeal filed by the assessee is allowed for\nstatistical purposes.\nOrder pronounced in the open

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

14-October-2025 Date of pronouncing the order : 09-December-2025 ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals)-I, Patna [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250(6) of the Income Tax Act, 1961 (hereinafter referred

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

14. For that any other ground, if any, may be urged at the time of hearing.” I.T.A. No.: 670/PAT/2024 Assessment Year: 2024-25 St. Johns Education Trust St. Johns Society for Education. 3. Rival contentions were heard and the submissions made have been examined. We will first take up the appeal in I.T.A. No.670/PAT/2024. Brief facts of the case

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

14. For that any other ground, if any, may be urged at the time of hearing.” I.T.A. No.: 670/PAT/2024 Assessment Year: 2024-25 St. Johns Education Trust St. Johns Society for Education. 3. Rival contentions were heard and the submissions made have been examined. We will first take up the appeal in I.T.A. No.670/PAT/2024. Brief facts of the case

M/S PARWATI EDUCATIONAL & WELFARE TRUST,PATNA vs. PR.CIT-CENTRAL, PATNA

In the result, both the appeals filed by the assessee are allowed

Bench: Sri Manish Borad & Sri Sonjoy Sarma)

Charitable Trust wherein the facts are almost similar, this Tribunal after considering the judicial precedence, quashed the revisionary proceedings u/s 263 of the Act observing as follows: “5. We have heard rival contentions and perused the facts on record carefully including the revisionary orders passed u/s 263 of the Act and various decisions cited before us. We note that

M/S PARWATI EDUCATIONAL & WELFARE TRUST,PATNA vs. PR.CIT-CENTRAL, PATNA

In the result, both the appeals filed by the assessee are allowed

Bench: Sri Manish Borad & Sri Sonjoy Sarma)

Charitable Trust wherein the facts are almost similar, this Tribunal after considering the judicial precedence, quashed the revisionary proceedings u/s 263 of the Act observing as follows: “5. We have heard rival contentions and perused the facts on record carefully including the revisionary orders passed u/s 263 of the Act and various decisions cited before us. We note that

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

14. For that the appellant is an accredited institution supported by Government, alternate claim for exemption u/s. 10(23C)(iiiad), the same may be appreciated, is not a new claim, but incidental to its activity of running an educational institution, and on which basis it had been claiming exemption in the past. It is true that equitable considerations

BIHAR STATE EDUCATIONAL INFRASTRUCTURE DEVELOPMENT CORP. LTD,PATNA vs. ACIT, EXEMPTION CIRCLE-1, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

charitable purpose, it registers some income in its balance-sheet will not per se make it to be a profit-making organization. An organization of this size has to maintain its infrastructure and the staff which needs money. This kind of seemingly apparent income is really not per se indicative of profit-making. The activities of the assessee are covered

ALOK KUMAR,MOTIHARI vs. ACIT, CENTRAL CIRCLE, MUZAFFARPUR

In the result, ITA No. 127/PAT/2019 is treated as allowed for statistical purposes, whereas ITA No

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

Charitable Trust, Safar Hashmi Educational and Welfare Society etc. He has amassed huge money for his personal purposes, namely making investments in immovable or movable properties either his name or in the name of his family members. A notice under section 153A was issued upon the assessee in both the years. The assessee has filed his return of income disclosing

ALOK KUMAR,MOTIHARI vs. ACIT, CENTRAL CIRCLE, MUZAFFARPUR

In the result, ITA No. 127/PAT/2019 is treated as allowed for statistical purposes, whereas ITA No

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

Charitable Trust, Safar Hashmi Educational and Welfare Society etc. He has amassed huge money for his personal purposes, namely making investments in immovable or movable properties either his name or in the name of his family members. A notice under section 153A was issued upon the assessee in both the years. The assessee has filed his return of income disclosing

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

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)

14, hence the grounds of appeal in the instant case are reproduced for reference: “1. The Ld. CIT(A) has erred in law as well as facts of the case in deleting the addition of Rs. 4,81,15,488/-ole surplus) in holding that the assessee has maintained separate books of account of the pharmacy whereas the assessee

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)

14, hence the grounds of appeal in the instant case are reproduced for reference: “1. The Ld. CIT(A) has erred in law as well as facts of the case in deleting the addition of Rs. 4,81,15,488/-ole surplus) in holding that the assessee has maintained separate books of account of the pharmacy whereas the assessee

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)

14, hence the grounds of appeal in the instant case are reproduced for reference: “1. The Ld. CIT(A) has erred in law as well as facts of the case in deleting the addition of Rs. 4,81,15,488/-ole surplus) in holding that the assessee has maintained separate books of account of the pharmacy whereas the assessee