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

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

143(2) and 142(1) of the Act were issued and duly served upon the assessee. The assessee Trust derives income from the activities of financial inclusion and for the year under consideration, was registered u/s 12AA of the Act vide registration no. 201/2011-12 dated 21.02.2012 by the CIT-I, Patna. During the course of the assessment proceeding, the details

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

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

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,\nprovisions of sections 11, 12 and 13 are only applicable for\ndetermining income. These

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

2. The issue in the first ground of appeals is against the order passed by the ld. PCIT (Central), Patna dated 25.08.2023 withdrawing the approval granted to the assessee-Society under section 10(23C)(vi) of the Income Tax Act (hereinafter referred to as the Act) for A.Ys. 2018-19 to 2021-22, which is wrong, arbitrary

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

2. The issue in the first ground of appeals is against the order passed by the ld. PCIT (Central), Patna dated 25.08.2023 withdrawing the approval granted to the assessee-Society under section 10(23C)(vi) of the Income Tax Act (hereinafter referred to as the Act) for A.Ys. 2018-19 to 2021-22, which is wrong, arbitrary

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

2. The issue in the first ground of appeals is against the order passed by the ld. PCIT (Central), Patna dated 25.08.2023 withdrawing the approval granted to the assessee-Society under section 10(23C)(vi) of the Income Tax Act (hereinafter referred to as the Act) for A.Ys. 2018-19 to 2021-22, which is wrong, arbitrary

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

2. The issue in the first ground of appeals is against the order passed by the ld. PCIT (Central), Patna dated 25.08.2023 withdrawing the approval granted to the assessee-Society under section 10(23C)(vi) of the Income Tax Act (hereinafter referred to as the Act) for A.Ys. 2018-19 to 2021-22, which is wrong, arbitrary

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

143(3)/147 of the Income- tax Act. 1961 on the total income of Rs.17,07,150/-. Charge interest as per provision of chapter-XVII of the Income-tax Act. 1961 (u/s. 234A, 234B, 234C). Issue demand notice and penalty proceedings are initiated u/s. 271D & u/s. 27IE”. 5. Dissatisfied with this reopening, the assessee carried the matter in appeal before

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)

143(3) of the Income Tax Act, 1961 on 23/03/2016.” 3. Before us, the Ld. DR argued the matter and stated that the pharmacy business was represented commercial activity and for this purpose the assessee had not maintained any separate books of accounts and thereby argued that the assessee was covered under the last limb of section 2

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)

143(3) of the Income Tax Act, 1961 on 23/03/2016.” 3. Before us, the Ld. DR argued the matter and stated that the pharmacy business was represented commercial activity and for this purpose the assessee had not maintained any separate books of accounts and thereby argued that the assessee was covered under the last limb of section 2

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)

143(3) of the Income Tax Act, 1961 on 23/03/2016.” 3. Before us, the Ld. DR argued the matter and stated that the pharmacy business was represented commercial activity and for this purpose the assessee had not maintained any separate books of accounts and thereby argued that the assessee was covered under the last limb of section 2

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

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

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)

143(3) r.w.s. 153A in the case of the appellant was passed on 28/12/2018. The learned PCIT issued notice under section 263 of The Income Tax Act, 1961 on 12/03/2021 by which the appellant was directed to show-cause by 18/03/2021 as to why the order under section 263 should not be passed. The appellant filed its reply

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)

143(3) r.w.s. 153A in the case of the appellant was passed on 28/12/2018. The learned PCIT issued notice under section 263 of The Income Tax Act, 1961 on 12/03/2021 by which the appellant was directed to show-cause by 18/03/2021 as to why the order under section 263 should not be passed. The appellant filed its reply