PAVITRA CRUZ SISTERS ASSOCIATION,AMBIKAPUR vs. INCOME TAX OFFICER, AMBIKAPUR

In the result, the appeal of assessee is allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.08/Rpr/2018 (ननधाारण वषा / Assessment Year :2014-2015) Pavitra Cruz Sisters Association, Vs Ito, Ambikapur Holy Cross Institute, Manendragarh Road, Ambikapur (C.G.) Pan No. : Aaaap 0283 H (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

1) or sub-section (2) or sub-section (3) or sub- section (3A) shall not apply in relation to any income of a trust or an institution, being profits and gains of business, unless the business is incidental to the attainment of the objectives of the trust or, as the case may be, institution, and separate books of account

DISHA EDUCATION SOCIETY,RAIPUR vs. COMMISSIONER OF INCOME TAX, EXEMPTION, BHOPAL

In the result ground of the appeal in the instant appeal of the assessee are allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./ Ita No.32&60/Rpr/2019 (Assessment Year:) M/S Disha Education Society, Vs Commissioner Of Income Tax, Disha Crown, Katchana Road. Exemption, Bhopal Shankar Nagar, Raipur (Chhattisgarh) Pan No. :Aaatd5249C : Shri R.B.Doshi, Ca "नधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By : Shri V.K.Singh, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 26/04/2023 घोषणा क" तार"ख/Date Of Pronouncement : 08/06/2023

25 to 40 (Jha Education) & 17 to 24 (Bimladevi Dharamprakash) of case law compilation. iii) In the case of Bimladevi Dharmprakash Jan Kalyan Nidhi Trust, Hon'ble ITAT gave specific finding that allegation of bogus donation is not proved. Such finding is in para no. 6 of the appellate order, PN 23 of case law compilation iv) In the case

DISHA EDUCATION SOCIETY,RAIPUR vs. COMMISSIONER OF INCOME TAX, EXEMPTION, BHOPAL

In the result ground of the appeal in the instant appeal of the assessee are allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./ Ita No.32&60/Rpr/2019 (Assessment Year:) M/S Disha Education Society, Vs Commissioner Of Income Tax, Disha Crown, Katchana Road. Exemption, Bhopal Shankar Nagar, Raipur (Chhattisgarh) Pan No. :Aaatd5249C : Shri R.B.Doshi, Ca "नधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By : Shri V.K.Singh, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 26/04/2023 घोषणा क" तार"ख/Date Of Pronouncement : 08/06/2023

25 to 40 (Jha Education) & 17 to 24 (Bimladevi Dharamprakash) of case law compilation. iii) In the case of Bimladevi Dharmprakash Jan Kalyan Nidhi Trust, Hon'ble ITAT gave specific finding that allegation of bogus donation is not proved. Such finding is in para no. 6 of the appellate order, PN 23 of case law compilation iv) In the case

GASS MEMORIAL CENTRE,RAIPUR vs. COMMISSIONER OF INCOME TAX ( EXEMPTION), BHOPAL

In the result, the appeal of assessee allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.02/Rpr/2019 (ननधाारण वषा / Assessment Year :2015-2016) Gass Memorial Centre, Vs Cit(Exemption), Bhopal Ground Floor, K.K. Road, Moudhapara, Raipur Pan No. : Aabhg 3026 M (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

1. Secs. 11 and 12 of the IT Act, 1961 exempt income of charitable trusts or institutions, if such income is applied for charitable purpose and such institution is registered under s. 12AA of the Act. 2. Sec. 2(15) of the Act provides definition of 'charitable purpose'. It includes 'advancement of any other object of general public utility' provided

NAYA RAIPUR DEVELOPMENT AUTHORITY,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), RAIPUR

The appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 174 & 63/Rpr/2019 "नधा"रण वष" / Assessment Year(S) : 2012-13 & 2013-14 Naya Raipur Development Authority Prayavas Bhawan, North Block, Sector 19, Naya Raipur Marg, Naya Raipur, Atal Nagar(C.G.) Pin-492 002. Pan : Aaalc0225H .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax (Exemption) Raipur (C.G.) ……""यथ" / Respondent Assessee By : S/Shri S.R Rao & Rajesh Kumar Chawda, Ar’S. Revenue By : Shri P.K. Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 09.06.2022 घोषणा क" तार"ख / Date Of Pronouncement : 02.09.2022

trust), declaring an income of Rs. Nil. Case of the assessee was thereafter selected for scrutiny assessment u/s.143(2) of the Act. 18. During the course of the assessment proceedings, the A.O called upon the assessee to explain as to how it was entitled to claim itself as a charitable institution on the ground that it was engaged

NAYA RAIPUR DEVELOPMENT AUTHORITY,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), RAIPUR

The appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 174 & 63/Rpr/2019 "नधा"रण वष" / Assessment Year(S) : 2012-13 & 2013-14 Naya Raipur Development Authority Prayavas Bhawan, North Block, Sector 19, Naya Raipur Marg, Naya Raipur, Atal Nagar(C.G.) Pin-492 002. Pan : Aaalc0225H .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax (Exemption) Raipur (C.G.) ……""यथ" / Respondent Assessee By : S/Shri S.R Rao & Rajesh Kumar Chawda, Ar’S. Revenue By : Shri P.K. Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 09.06.2022 घोषणा क" तार"ख / Date Of Pronouncement : 02.09.2022

trust), declaring an income of Rs. Nil. Case of the assessee was thereafter selected for scrutiny assessment u/s.143(2) of the Act. 18. During the course of the assessment proceedings, the A.O called upon the assessee to explain as to how it was entitled to claim itself as a charitable institution on the ground that it was engaged

CHHATTISGARH HOUSING BOARD,RAIPUR vs. EXEMPTION CIRCLE, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

charitable nature by virtue of section 2(15) first and second provision. 6.2.6 The appellant has tried to justify on the issues of contract receipts stating along with providing housing for LIG and weaker section we also works as nodal agency to the state government thus also construct houses and other buildings on the behalf of the government

CHHATTISGARH HOUSING BOARD,RAIPUR vs. ASSISTANT COMMISSIONER, EXEMPTION CIRCLE, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

charitable nature by virtue of section 2(15) first and second provision. 6.2.6 The appellant has tried to justify on the issues of contract receipts stating along with providing housing for LIG and weaker section we also works as nodal agency to the state government thus also construct houses and other buildings on the behalf of the government

CHHATTISGARH HOUSING BOARD,RAIPUR vs. EXEMPTION CIRCLE, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

charitable nature by virtue of section 2(15) first and second provision. 6.2.6 The appellant has tried to justify on the issues of contract receipts stating along with providing housing for LIG and weaker section we also works as nodal agency to the state government thus also construct houses and other buildings on the behalf of the government

CHHATTISGARH HOUSING BOARD,RAIPUR vs. ASSISTANT COMMISSIONER, EXEMPTION CIRCLE, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

charitable nature by virtue of section 2(15) first and second provision. 6.2.6 The appellant has tried to justify on the issues of contract receipts stating along with providing housing for LIG and weaker section we also works as nodal agency to the state government thus also construct houses and other buildings on the behalf of the government

CHHATTISGARH HOUSING BOARD,RAIPUR vs. ASSISTANT COMMISSIONER, EXEMPTION CIRCLE,, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

charitable nature by virtue of section 2(15) first and second provision. 6.2.6 The appellant has tried to justify on the issues of contract receipts stating along with providing housing for LIG and weaker section we also works as nodal agency to the state government thus also construct houses and other buildings on the behalf of the government

THE REDIANT WAY SCHOOL,RAIPUR (CG) vs. THE THE CHIF COMMISIONER OF INCOME TAX, RAIPUR (CG)

In the result, the appeal of assessee is allowed

25 of the order that "....... In view of these reasons, the order impugned of the Tribunal rejecting the appeal of the assessee mainly on the ground of delay, is liable to be interfered with" In the instant case also, the section 253(l)(c) was amended from 1.06.2015 and recovery notice was received after almost 2 and half year years

DY. C.I.T.1(1), BILASPUR(CG) vs. JSPL,, RAIGARH(C.G)

In the result, the appeal is partly allowed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member Dcit-1(1), Bilaspur- Vs Jspl, 495004 Kharsia Road, Raighagh(Cg) Pan No. : Aabcj 4683 J (Appellant) .. Tsednepser Revenue By : Shri Sanjay Kumar, Dr Assessee By : Shri Mayank Jain, Ar Date Of Hearing : 12/01/2018 Date Of Pronouncement 15/01/2018 आदेश / O R D E R Per Shri N.S.Saini, Am: This Is An Appeal Filed By The Revenue Against The Order Of The Cit(A), Bilaspur, Dated 31.03.2014 For The Assessment Year 2009-2010. 2. The Sole Grievance Of The Revenue Is That The Cit(A) Erred In Deleting The Amount To The Extent Of Rs.2,10,89,707/- Out Of Disallowance Of Rs.3,36,18,098/- Made By The Ao Under The Head Corporate Social Responsibility Expenses. 3. Brief Facts Of The Case Are That The Assessee Is A Domestic Company, A Subsidiary Of Jindal Steel &.Power Limited (Jspl). It Derives Income From Power Generation & Mining. The Company Has Commenced The Commercial Generation Of Thermal Power From Its First Of The Four Units Of 250Mw Each From 08.12.2007. The Assessee Company Filed Its Income Tax Return For The Year Under Consideration Declaring

section 135 the Corporate Social Responsibility (CSR) has been made mandatory for companies having net worth of Rs. 500 crores or more OR having turnover of Rs. 1000 crore or more OR having net profit of Rs. 5 crores or more during any financial year, such company has to expend minimum 2% of net profit in CSR activities

SHRI SHRI MAHESH KUMAR DUHLANI,KORBA(CG) vs. THE DY. COMMISSIONER OF INCOME TAX,CIRCLE , KORBA, KORBA(CG)

In the result, the appeal of the assessee is allowed

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 92/Bil/2017 "नधा"रण वष" / Assessment Year : 2011-12 Shri Mahesh Kumar Duhlani Main Road, P. O. Katoghora, Distt. Korba (C.G) Pan : Aejpd4102K .......अपीलाथ" / Appellant बनाम / V/S. Deputy Commissioner Of Income Tax, Circle Mahanadi Complex, Niharika Road, Korba (Cg) ……""यथ" / Respondent Assessee By : Shri G. S. Agrawal Revenue By : Shri G. N. Singh सुनवाई क" तार"ख / Date Of Hearing : 06.06.2022 घोषणा क" तार"ख / Date Of Pronouncement : 09.06.2022

1 as the lender is the wife of Shri Vikas agrawal who is father of Smt Sharda Devi Agrawal. The most of the amount received by the assessee by loan in coming from two families and all have deposited cash in their accounts before advancing loan to the assessee. The opening capital balance of Smt. Sharda Devi Agrawal is 25

M/S ADHARSHILA SHIKSHAN SANGH,RAIPUR (CG) vs. C.I.T-, RAIPUR (CG)

In the result, the appeal of the assessee is allowed

Bench: Shri Anil Chaturvedi, Am & Shri Partha Sarathi Chaudhury, Jm

25-08-2014 passed u/s. 80G rejected the application for approval u/s. 80G inter alia for reason that the assessee society was engaged in commercial activities and the activities conducted by assessee cannot be considered as charitable activities. Aggrieved by the order of Commissioner of Income Tax, the assessee is now before us and has raised following grounds : “1. That