JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

trust under section 11 of the Act. During the relevant assessment years impugned in these appeals, there is no such provision in the Act that in case return is not filed by charitable society under section 139(4A), then its income cannot to be computed in accordance with the provision of the Act. 21. Further, on going through the provisions

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

trust under section 11 of the Act. During the relevant assessment years impugned in these appeals, there is no such provision in the Act that in case return is not filed by charitable society under section 139(4A), then its income cannot to be computed in accordance with the provision of the Act. 21. Further, on going through the provisions

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

trust under section 11 of the Act. During the relevant assessment years impugned in these appeals, there is no such provision in the Act that in case return is not filed by charitable society under section 139(4A), then its income cannot to be computed in accordance with the provision of the Act. 21. Further, on going through the provisions

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

trust under section 11 of the Act. During the relevant assessment years impugned in these appeals, there is no such provision in the Act that in case return is not filed by charitable society under section 139(4A), then its income cannot to be computed in accordance with the provision of the Act. 21. Further, on going through the provisions

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

Bench: Shri R. K. Panda & Ms Astha Chandra

trust under section 11 of the Act. During the relevant assessment years impugned in these appeals, there is no such provision in the Act that in case return is not filed by charitable society under section 139(4A), then its income cannot to be computed in accordance with the provision of the Act. 21. Further, on going through the provisions

SHETH CHIMANLAL GOVINDDAS MEMORIAL TRUST,PUNE vs. CIT(EXEMPTION), PUNE, PUNE

In the result, appeal of the assessee is dismissed

144B of the Income Tax Act, 1961 dated 26.09.2022. The\nassessee has raised following grounds of appeal :\nITA No.1224/PUN/2025 [A]\n“1. The Order under section 263 dated 29 03 2025 passed by the\nlearned Commissioner Income Tax Exemption Pune (CIT) is contrary to\nthe facts and circumstances of the cave and the law and thus needs

ASHIRWAD CHARITABLE TRUST,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS) CIRCLE, PUNE

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

Bench: Shri R.K. Panda & Ms. Astha Chandra

trust are not charitable as per the provisions of section 2(15) of the Act. On appeal against such assessment order passed 2 ITA No.190/PUN/2024, A.Y. 2015-16 u/s 143(3) of the Act, the Ld. CIT(A) vide his order dated 06-12-2023 allowed the appeal of the assessee holding that the assessee has to be given

BANSILAL RAMNATH AGARWAL CHARITABLE TRUST,PUNE vs. CIT (EXEMPTION), PUNE

In the result, the appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Bansilal Ramnath Agarwal Charitable Trust Cit (Exemption), 251, Budhwar Peth, City Post Chowk, Vs. Pune Pune – 411002 Pan: Aaatb4383K (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 11-12-2025 Date Of Pronouncement : 28-01-2026 O R D E R Per R.K. Panda, V.P:

charitable trust and its related concerns are excessive and lack commercial prudence, the trust forfeits exemption under Section 11. He further noted that in the case of M/s Agrabh also 100% of the revenue is received from the assessee only. Since the Assessing Officer in the instant case has passed the order without scrutinizing the commercial viability, necessity and reasonableness

SHAHU SHIKSHAN PRASARAK MANDAL, LATUR,LATUR vs. ACIT (EXMP.) CIRCLE, AURANGABAD, AURANGABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

charitable trust exclusively engaged in imparting\nof recognized educational courses. Moreover, the institution is\nsubstantially financed by the Government, therefore, whole of the\nincome of the trust is exempted u/s. 10(23C) (iiiab) of the Act.\nTherefore, the assessee trust was required to submit its return in ITR-\n7. Whereas, by mistake, ITR 5 is submitted.\nYour honour, in order

GOURISHANKAR EDUCATION SOCIETY,SATARA vs. CIT EXEMPTION, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1234 & 1235/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Gourishankar Education Vs. Cit, Exemption, Pune. Society, Panchganga Apartment, Opp. Axis Bank, Radhika Road, Satara- 415001. Pan : Aaatg6668A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement 10.01.2025 : आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 30.03.2024 Passed By Ld. Cit, Exemption, Pune U/S 263 Of The It Act For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1234/Pun/2024 For A.Y. 2013-14 For Adjudication.

144B of the ITA, 1961 dated 16/03/2022 is erroneous and prejudicial to the interest of the revenue. 2. The learned CIT(E), Pune erred in law and on facts in directing the learned AO to frame the assessment 'de novo' instead of giving specific directions. As such, the order passed u/s 263 of the ITA, 1961 is erroneous

GOURISHANKAR EDUCATION SOCIETY,SATARA vs. CIT EXEMPTION, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1234 & 1235/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Gourishankar Education Vs. Cit, Exemption, Pune. Society, Panchganga Apartment, Opp. Axis Bank, Radhika Road, Satara- 415001. Pan : Aaatg6668A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement 10.01.2025 : आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 30.03.2024 Passed By Ld. Cit, Exemption, Pune U/S 263 Of The It Act For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1234/Pun/2024 For A.Y. 2013-14 For Adjudication.

144B of the ITA, 1961 dated 16/03/2022 is erroneous and prejudicial to the interest of the revenue. 2. The learned CIT(E), Pune erred in law and on facts in directing the learned AO to frame the assessment 'de novo' instead of giving specific directions. As such, the order passed u/s 263 of the ITA, 1961 is erroneous

VIDYARTHI VIKAS PRATISHTHAN JALGAON,JALGAON vs. INCOME TAX DEPARTMENT (NFAC), DELHI

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.1194/Pun/2023 िनधा"रणवष" / Assessment Year : 2020-21 Vidyarthi Vikas Pratishthan Assessment Unit, Income Jalgaon, V Tax Department(Nfac) Gat No.148, Yashwant Nagar, S Ramanand Nagar, Maharashtra – 425001. Pan: Aaatv6624R Appellant/ Assessee Respondent /Revenue Assessee By Shri Hari Krishnan – Ar Revenue By Shri Sourabh Nayak – Jcit-Dr Date Of Hearing 01/02/2024 Date Of Pronouncement 02/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Delhi Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Passed On 20.09.2023 Emanating From Order Under Section 143(3) R.W.S 144B Of The Income Tax Act, 1961 Dated 20.09.2022. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A) Has Erred In Dismissing The Grounds Of Appeal Filed Before Him By The Assessee & In Vidyarthi Vikas Pratishthan Jalgaon[A]

section 143(3) r.w.s 144B of the Income Tax Act, 1961 dated 20.09.2022. The assessee has raised the following grounds of appeal : “1. The Learned CIT(A) has erred in dismissing the grounds of appeal filed before him by the assessee and in Vidyarthi Vikas Pratishthan Jalgaon[A] confirming the arbitrary and adhoc disallowance of Rs.53,56,317/- being

ASSTT. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE, PUNE, PUNE vs. THE SHETKARI SHIKSHAN MANDAL, PUNE

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

Bench: Shri R.K. Panda & Ms. Astha Chandra

Trust. Therefore, a total amount of Rs. 10,72,20,634/- according to the Assessing Officer, had been incorrectly claimed by the assessee as application of income and therefore the same was required to be disallowed being under assessed in the assessment made earlier. 2.2 The Assessing Officer also found that the assessee had claimed an amount

VIDYA VIKAS PRATISHTAN,SOLAPUR vs. DCIT, EXEMPTION CIRCLE, PUNE

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

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.902/Pun/2025 िनधा"रण वष" / Assessment Year : 2022-23 Vidya Vikas Pratishtan, Vs. Assessment Unit, 72/2B, Pratap Nagar, Income Tax Department. Soregaon, Solapur- 413004. Pan : Aaatv8537F Appellant Respondent Assessee By : Shri Piyush Bafna Revenue By : Shri Amit Bobde Date Of Hearing : 18.08.2025 Date Of Pronouncement : 29.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.12.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2022-23. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeal.

section 143(3) r.w.s. 144B of the Act is bad in law, as it is based entirely on best judgment without adequate opportunity of hearing, and in violation of principles of natural justice. 6. On the facts and in the circumstances of the case and without prejudice to any other grounds, the learned authorities failed to 3 appreciate that

GAURISHANKAR EDUCATIION SOCIETY,SATARA vs. THE INCOME TAX OFFICER(EXEMPTION), WARD-1(1), PUNE

Appeals of the assessee are PARTLY ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 982 To 985/Pun/2023 निर्धारण वषा / Assessment Year : 2013-14 To 2016-17 Gaurishankar Education Society, Grahak Sangh, Market Yard, Satara - 415 001 Pan: Aaatg666A . . . . . . . अपऩलधर्थी / Appellant

Charitable Trust’ [hereafter ‘GECT’], wherein it was discovered that, the appellant assessee was operating from premises of GECT with common trustees on board, had advanced an interest-free loan of ₹3.30Crores to GECT out of its interest bearing loans availed from various bankers etc. 4.3 In view of the Ld. National Faceless e-Assessment Centre [hereafter ‘NeAC’], the aforestated

GAURISHANKAR EDUCATIION SOCIETY,SATARA vs. THE INCOME TAX OFFICER(EXEMPTION), WARD-1(1), PUNE

Appeals of the assessee are PARTLY ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 982 To 985/Pun/2023 निर्धारण वषा / Assessment Year : 2013-14 To 2016-17 Gaurishankar Education Society, Grahak Sangh, Market Yard, Satara - 415 001 Pan: Aaatg666A . . . . . . . अपऩलधर्थी / Appellant

Charitable Trust’ [hereafter ‘GECT’], wherein it was discovered that, the appellant assessee was operating from premises of GECT with common trustees on board, had advanced an interest-free loan of ₹3.30Crores to GECT out of its interest bearing loans availed from various bankers etc. 4.3 In view of the Ld. National Faceless e-Assessment Centre [hereafter ‘NeAC’], the aforestated

GAURISHANKAR EDUCATIION SOCIETY,SATARA vs. THE INCOME TAX OFFICER(EXEMPTION), WARD-1(1), PUNE

Appeals of the assessee are PARTLY ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 982 To 985/Pun/2023 निर्धारण वषा / Assessment Year : 2013-14 To 2016-17 Gaurishankar Education Society, Grahak Sangh, Market Yard, Satara - 415 001 Pan: Aaatg666A . . . . . . . अपऩलधर्थी / Appellant

Charitable Trust’ [hereafter ‘GECT’], wherein it was discovered that, the appellant assessee was operating from premises of GECT with common trustees on board, had advanced an interest-free loan of ₹3.30Crores to GECT out of its interest bearing loans availed from various bankers etc. 4.3 In view of the Ld. National Faceless e-Assessment Centre [hereafter ‘NeAC’], the aforestated

GAURISHANKAR EDUCATIION SOCIETY,SATARA vs. THE INCOME TAX OFFICER(EXEMPTION), WARD-1(1), PUNE

Appeals of the assessee are PARTLY ALLOWED

Bench: Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 982 To 985/Pun/2023 निर्धारण वषा / Assessment Year : 2013-14 To 2016-17 Gaurishankar Education Society, Grahak Sangh, Market Yard, Satara - 415 001 Pan: Aaatg666A . . . . . . . अपऩलधर्थी / Appellant

Charitable Trust’ [hereafter ‘GECT’], wherein it was discovered that, the appellant assessee was operating from premises of GECT with common trustees on board, had advanced an interest-free loan of ₹3.30Crores to GECT out of its interest bearing loans availed from various bankers etc. 4.3 In view of the Ld. National Faceless e-Assessment Centre [hereafter ‘NeAC’], the aforestated

P Y C HINDU GYMKHANA,PUNE vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE

In the result, the appeal filed by the assessee is partly allowed

Bench: Dr.Manish Borad & Shri Vinay Bhamore

trust. Assessee in its submission has stated that all these details were filed before the ld. AO which have been thoroughly examined during the course of assessment proceedings and further stated that since the alleged receipts of income from rent, collecting event receipts, Gymkhana subscribers etc. at Rs.81,34,015/- is less than 20% of the gross receipts of Rs.5