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

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 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

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

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraι.Τ.Α. No.: 223/Pat/2023

1)(b) of the Act. The applicant is a Trust. The address of the Trust is Waliganj, Arrah. The Ld. CIT (Exemption) issued a letter dated 20.12.2022 requiring the assessee to Page | 3 Ι.Τ.Α. No.: 223/PAT/2023 Assessment Year: 2023-24 Faridi Foundation. submit the documents related to notes on activities undertaken by the applicant during the last three

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

charitable purpose and not any business or profession. 2. FOR THAT Ld. CIT(A) erred in law and on the facts in confirming action of AO assessing income of the appellant Trust at Rs 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

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)

charitable purpose” u/s 2(15) of the Act. For more clarity, on this issue the matter deserves to be remanded back to the Ld. AO for exactly determining under which object defined in section 2(15) of the Act does the activity of the assessee falls in. Furthermore, the addition made while 6 ITA Nos. 65-67/Pat/2020

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)

charitable purpose” u/s 2(15) of the Act. For more clarity, on this issue the matter deserves to be remanded back to the Ld. AO for exactly determining under which object defined in section 2(15) of the Act does the activity of the assessee falls in. Furthermore, the addition made while 6 ITA Nos. 65-67/Pat/2020

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)

charitable purpose” u/s 2(15) of the Act. For more clarity, on this issue the matter deserves to be remanded back to the Ld. AO for exactly determining under which object defined in section 2(15) of the Act does the activity of the assessee falls in. Furthermore, the addition made while 6 ITA Nos. 65-67/Pat/2020

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

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.

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 to tax only on the ground that the trust was not registered under Section 12 A of the Income

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

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

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

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

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

15, 2022 Date of pronouncing the order : February 21st , 2022 O R D E R Per Shri Rajpal Yadav, Vice-President (KZ):- The assessee is in appeal before the Tribunal against the order of ld. Commissioner of Income Tax (Exemption), Patna dated 17.07.2018 passed under section 12AA(1)(b)(ii) of the Income Tax Act, 1961. 2. The solitary grievance