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

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

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

250(6) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2014-15 dated 24.11.2017. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. FOR THAT Ld. CIT(A) erred in law and on the facts in confirming action of A.O. in holding that the appellant trust carried

NARAYANI EDUCATIONAL HEALTH AND CHARITABLE TRUST ,PATNA vs. DCIT,CENTRAL CIRCLE-2, PATNA , PATNA

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

Section 250(6) of the Act. Therefore, in the interest of justice and fair play, these appeals are restored to the file of the learned CIT (A) with a direction to decide the same on merit after affording reasonable opportunity of hearing to the assessee. It is further clarified that assessee should also not seek any adjournments unless otherwise required

NARAYANI EDUCATIONAL HEALTH AND CHARITABLE TRUST,PATNA vs. DCIT, CENTRAL CIRCLE-2, PATNA

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

Section 250(6) of the Act. Therefore, in the interest of justice and fair play, these appeals are restored to the file of the learned CIT (A) with a direction to decide the same on merit after affording reasonable opportunity of hearing to the assessee. It is further clarified that assessee should also not seek any adjournments unless otherwise required

NARAYANI EDUCATIONAL HEALTH AND CHARITABLE TRUST ,PATNA vs. DCIT, CENTRAL CIRCLE-2,PATNA , PATNA

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

Section 250(6) of the Act. Therefore, in the interest of justice and fair play, these appeals are restored to the file of the learned CIT (A) with a direction to decide the same on merit after affording reasonable opportunity of hearing to the assessee. It is further clarified that assessee should also not seek any adjournments unless otherwise required

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

250 of the Income Tax Act, 1961 (hereinafter referred to as\n'the Act') for AY 2018-19 dated 19.08.2025.\n\n2. The assessee is in appeal before the Tribunal raising the following\ngrounds of appeal:\n\n“1. That the order passed by the Learned CIT(A) is bad in law and\nunsustainable on facts.\n\n2. That

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.

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

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)

250 of the Income Tax Act, 1961 (hereafter ‘the Act’), passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 07.02.2024. 1.1 In this case, the assessee is a 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

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

250 of the Income Tax Act, 1961 (hereinafter referred to as the "Act") for Assessment Year 2019- 20. 2. It is seen that in this case, the assessee filed an appeal before 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

ALMAHAD TRUST ,PATNA vs. ITO EXEMPTION, WARD-1, PATNA , PATNA

In the result, appeal of the assessee is allowed for statistical purposes

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

6. For that the learned Commissioner of Income Tax (Appeals) has erred in not considering the issue of applicability of section 69A of the Act. 7. For that other various grounds which may be urged at the time of hearing.” 2. At the outset of hearing, we noted that the appeal filed by the assessee is delay by 355 days

MAGADH HOMIOPATHIK MEDICAL COLLAGE AND HOSPITAL,BIHAR SHARIF vs. INCOME TAX OFFICER WARD 1, PATNA

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

250 of the Act is mentioned as 24/03/2025 and the date of receipt the order is mentioned as 20/06/2025. The limitation arises from the date of receipt of the order of the first appellate ITA No.: 334/PAT/2025 Assessment Year: 2018-19 Magadh Homiopathik Medical College And Hospital authority. Since the appeal has been filed on 16/07/2025, the same is within

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

250(6) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2012-13 dated 09.07.2018, I.T.A. No.: 344/PAT/2018 Assessment Year: 2012-13 Bihar State Educational Infrastructure Development Corp. Ltd. which has been passed against the assessment order u/s 143(3) of the Act, dated 31.03.2015. 1.1. The Registry has informed that the appeal filed

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)

6 Military Flats, S.K. Puri, Bihar - 800001 [PAN: AAATD9423G] ..........…..….................... Respondent Appearances by: Assessee represented by : None Department represented by : Ashok Kumar, CIT Date of concluding the hearing : 01.01.2025 Date of pronouncing the order : 10.01.2025 O R D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. In the present three matters it is seen that there is a delay in filing

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)

6 Military Flats, S.K. Puri, Bihar - 800001 [PAN: AAATD9423G] ..........…..….................... Respondent Appearances by: Assessee represented by : None Department represented by : Ashok Kumar, CIT Date of concluding the hearing : 01.01.2025 Date of pronouncing the order : 10.01.2025 O R D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. In the present three matters it is seen that there is a delay in filing

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)

6 Military Flats, S.K. Puri, Bihar - 800001 [PAN: AAATD9423G] ..........…..….................... Respondent Appearances by: Assessee represented by : None Department represented by : Ashok Kumar, CIT Date of concluding the hearing : 01.01.2025 Date of pronouncing the order : 10.01.2025 O R D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. In the present three matters it is seen that there is a delay in filing

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

250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2018-19 dated 25.06.2024. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that the order passed by learned Commission of Income-tax (Appeals) confirming the order passed by CPC, Bengaluru is bad in law as well