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

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

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 referred to the explanation (2) of Section 263 as inserted w.e.f. 01.06.2015 which provides in clears words that the PCIT can revise the assessment if in his opinion the AO has not made the enquiry or not examined the issues which should have been made. The Ld. D.R. submitted that even in the set aside proceedings , the assessee

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 referred to the explanation (2) of Section 263 as inserted w.e.f. 01.06.2015 which provides in clears words that the PCIT can revise the assessment if in his opinion the AO has not made the enquiry or not examined the issues which should have been made. The Ld. D.R. submitted that even in the set aside proceedings , the assessee

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 referred to the explanation (2) of Section 263 as inserted w.e.f. 01.06.2015 which provides in clears words that the PCIT can revise the assessment if in his opinion the AO has not made the enquiry or not examined the issues which should have been made. The Ld. D.R. submitted that even in the set aside proceedings , the assessee

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 referred to the explanation (2) of Section 263 as inserted w.e.f. 01.06.2015 which provides in clears words that the PCIT can revise the assessment if in his opinion the AO has not made the enquiry or not examined the issues which should have been made. The Ld. D.R. submitted that even in the set aside proceedings , the assessee

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

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

Trust wholly for religious and charitable\npurposes. In the result, the application filed in Form 10AB for grant of\nregular registration under sub clause (iii) of clause (ac) of sub-section (1) of\nsection 12A is rejected.\nPage | 6\nI.Τ.Α. No.: 223/PAT/2023\n Assessment Year: 2023-24\nFaridi Foundation.\n7. Accordingly, the provisional registration granted u/s 12A(1

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

2) The provisions of sub-section (1) shall not apply to any anonymous donation received by— (a) any trust or institution created or established wholly for religious purposes; (b) any trust or institution created or established wholly for religious and charitable

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

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

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

1) along with questionnaire was issued to the assessee on 26/ 11/2019 compliance on 03 12/2019. The assessee filed return of income u/s 148 on 27/12/2019, disclosing total income of Rs.17,07,150/-. Notice u/s 143(2) was issued to the assessee on 27/12/2019 for compliance on 30/12/2019. The reason of reopening of assessment

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

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

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(1

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(1