SHREE MALIYA KADVA PATEL SEVA SAMAJ,,JUNAGADH vs. THE INCOME TAX OFFICER, WARD-1(3),, VERAVAL

Appeal of the assessee is dismissed in above terms

income is computed at Rs. 15,51,780/-. Propositions against the addition in appeal may be stated in nutshell as under: I. TRUST IS NOT CREATED OR ESTBALISHED ONLY FOR KADVA PATIDARS BUT FOR ALL PEOPLE OF SOCIETY ALSO: 1. The appellant-trust submitted before lower authorities and reiterates that it is not created or established for any particular community

SHRI UMIYA MATAJI ISHVER RAMJI ANNAKSHETRA TRUST,BHUJ KUTCH vs. CIT (EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical purpose, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.116/Rjt/2025 "नधा"रण वष"/ Assessment Year: N.A. Shri Umiya Mataji Ishver Ramji Commissioner Of Income- बनाम Annakshetra Trust Tax(Exemption), Ahmedabad, Vadhay At Deshalpar Vandhay Room No.609, 6Th Floor, Vs. Taluka Bhuj Kutch-370 001 Ayakar Bhawan (Vejalpur), Pan : Aabts 8429 C Nr. Sacin Tower 100 Ft Road, Anandnagar Prahladnagar Road, Ahmedabad-3800 015 (अपीलाथ"/Assessee) (""यथ"/Respondent) :

Additionally, the assessee-trust also Shri Umiya Mataji Ishver Ramji Annakshetra Trust 10 arranges Mass Marriage functions for needy families. The details of the income and the object related expense incurred by the assessee-trust for the preceding three years are as under: Sr. Financial Total income Expenditure of Percentage to total No. Year religious nature income

SHRI SHAMJIBHAI HARJIBHAI TALAVIA CHARITABLE TRUST,RAJKOT vs. THE PR. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

The appeal of the assessee is dismissed

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal(Through Web-Based Video Conferencing Platform) िनधा"रणवष"/Assessment Year: 2015-16 Shri Shamjibhai Harjibhai Talavia Vs. The Pr. Commissioner Of Charitable Trust, Income-Tax (Exemption), 50 Feet Road, 7-Parsana Society, Ahmedabad Rajkot-360002 Pan : Aacts 8845 F अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Mehul Ranpura, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 04.09.2023 घोषणा क" तारीख /Date Of Pronouncement: 04.12.2023 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income-Tax (Exemptions), Ahmedabad [Herein-After Referred To As “Cit(Exemptions)”] Dated 23.03.2021, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year 2015-16. 2. The Assessee Has Raised Following Grounds Challenging The Validity Of Revisionary Jurisdiction Exercised By The Ld. Cit (Exemptions) In The Present Case:- “1. The Grounds Of Appeal Mentioned Hereunder Are Without Prejudice To One Another. 2. The Order Passed By Pr. Commissioner Of Income-Tax (Exemption), Ahmedabad [Hereinafter Referred As To The “Pr. Cit”] Is Bad & Illegal & Requires To Be Quashed.

addition of this institute in the assessee-trust subsequent to the grant of approval i.e. in the year 2014 this institute was added to the trust while the approval u/s 10(23C)(vi) of the Act was granted in the year 2012. 8 Shri Shamjibhai Harjibhai Talavia Charitable Trust Vs. PCIT(E) AY : 2015-16 12. In the light

DR. SUBHASH PETHALJI CHAVDA AHIR KELVANI MANDAL,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER(EXEMPTION), WARD-2,, RAJKOT

The appeal of the assessee is allowed

trust. In view of the above, it is seen that there is willful attempt of concealment of income and misguide the department to conceal the liability of tax. Penalty proceedings u/s 271(l)(c) of the I.T.Act is initiated for concealment of income by way of furnishing in accurate particulars of its income. 3. And that

SHREE SANATAN ASHRAM CHARITABLE TRUST,,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER, WARD-2 (4),, AMRELI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No.178/Rjt/2016 ("नधा"रण वष"/Assessment Year : 2011-12) Shree Santan Ashram The I.T.O. बनाम/ Charitable Trust Ward-2(4) Vs. Shree Chamunda Temple Amreli Vankiya Bhod Khamba "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aajts 7402 B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : None (Written Submission) ""यथ" क" ओर से/Respondent By: Shri Praveen Verma, Sr.Dr

Charitable Trust vs. ITO Asst.Year 2011-12 1. The Ld. CIT(A) has erred in law and facts in treating the assessee as not liable of earning income as exempt from income-tax for A.Y. 2011-12 and there by confirming total addition

ASHOK GONDHIA MEMORIAL TRUST,RAJKOT vs. THE ITO EXEMPTION, WARD -1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

addition treating the assessee- trust, as if, assessee-trust is engaged in commercial activity, therefore, the hospital management fees receipt of Rs. 2,30,00,004/- received from M/S. Wockhardt Hospitals Ltd was treated as income from business/commercial activities of the assessee and added as income of the assessee -trust. Aggrieved by the order of assessing officer, the assessee carried

SHRI TUNDA JAIN MAHAJANWADI,KUTCH vs. CIT(EXEMPTION), AHMEDABAD

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.358/Rjt/2024 ("नधा"रण वष" / Assessment Year: N.A.) Shri Tunda Jain Mahajanwadi, Vs. Commissioner Of Income Tax (Exemption), Tunda, Mundra, Kutch, Gujarat- Ahmedabad 370435 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abfts8536F (Assessee) (Respondent)

charitable purpose. Therefore, learned CIT(E) noted that the assessee has violated the above referred provisions of the Income Tax Act and hence the assessee is not entitled to get approval u/s. 80G(5) of the Income Tax Act, therefore the assessee`s application filed in Form 10AB was rejected by ld.CIT(E ). 6. Aggrieved by the order

PATEL KELAVANI MANDAL,TAPOVAN SHAIKSHNIK SANKUL vs. THE ITO (EXEMPTION), WARD - 2, RAJKOT, AAYAKAR BHAVAN

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini, Am. & Diesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 278/Rjt/2023 (िनधा"रणवष" / Assessment Year: (2010-11) (Hybrid Hearing) Patel Kelavani Mandal, Junagadh. Vs. The Ito (E), Ward – 2, Tapovan Shaikshnik Sankul, Aaykar Bhavan, Bilkha Road, Race Course Ring Road, Junagadh - 362001 Rajkot - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabtp7542H (Appellant) (Respondent)

Charitable Trust, is running different types of educational institutions. The assessee has been registered u/s.12AA of the Act w.e.f. AY 2015-16. As such, for the impugned AY 2010-11, the assessee is not entitled to claim exemption of its income u/s.11, 12 and 13 of the Act. The assessee did not file its return of income for the impugned

DASHA SHRIMALI KANDOI GNATI,RAJKOT vs. COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD

The appeal of the assessee is allowed, for statistical purpose

Bench: Dr. Arjun Lal Saini & Shri Diesh Mohan Sinha

charitable for a particular cast, i.e. Dasha Shrimali Kandoi Ganti. However, as per the Explanation 2 of Section 13 of the Income Tax Act, 1961, the trust is not created or established for the benefit of the Scheduled castes, backward classes, scheduled tribes or women and children. In addition

VIDHYASAGAR CHARITABLE TRUST,RAJKOT vs. THE ITO WARD-1, RAJKOT, RAJKOT

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Charitable Trust vs. ITO(E) Asst.Year –2011-12 with reason for seeking adjournment "Gathering of materials from multiple sources require time and for preparing submission". (2) The Learned C.I.T.(A) had without considering the adjournment request uploaded on portal finalised the order dt.15/02/2023 by confirming addition of Rs.22,00,000/- in hands of the Trust and raised demand of Rs.8

KRUPA VILAS GAU SEVA TRUST,KUTCH vs. CIT(EXEMPTION), AHMEDABAD

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 162/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing) Krupa Vilas Gau Seva Trust, Vs. Cit(Exemption), Kutch. Ahmedabad. Anjar, Anjar Road, Bhimasar Taluka Anjar, Kutch-370240. स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaetk8746K (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No. 163/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing) Krupa Vilas Gau Seva Trust, Vs. Cit(Exemption), Kutch. Ahmedabad. Anjar, Anjar Road, Bhimasar Taluka Anjar, Kutch-370240. स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaetk8746K (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) निर्धारितीकीओरसे/Assessee By : Shri Kalpesh Doshi, Ar राजस्वकीओरसे/Respondent By : Shri Sanjay Punglia, Cit Dr सुनवाईकीतारीख / Date Of Hearing : 09/01/2025 घोषणाकीतारीख / Date Of Pronouncement : 24/03/2025 1 | Page

addition to the primary focus on animal welfare, the assessee- trust has also been involved in distributing blankets to the needy people, which is charitable activity aimed of providing relief to vulnerable individuals. Therefore, distribution of blankets is in consonance with the charitable objectives of the trust. Therefore, it is incorrect to assert that the blanket distribution is not aligned

KRUPA VILAS GAU SEVA TRUST,KUTCH vs. CIT(EXEMPTION), AHMEDABAD

Appeals of the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 162/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing)

addition to the primary focus on animal welfare, the assessee- trust has also been involved in distributing blankets to the needy people, which is charitable activity aimed of providing relief to vulnerable individuals. Therefore, distribution of blankets is in consonance with the charitable objectives of the trust. Therefore, it is incorrect to assert that the blanket distribution is not aligned

SHREE SWAMINARAYAN MANDIR TRUST ,RAMPAR vs. THE ITO, EXEMPTION WARD - 1, RAJKOT

In the result, appeal filed by the assessee is allowed for statistical purpose, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.340/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2020-21)

addition of Rs. 23,98,804/- by treating entire income earned during the year as unexplained money u/s 69A of the Act. 3. The learned Commissioner of Income-tax (Appeals), Income Tax Department NFAC, Delhi failed to appreciate that alternatively, only net income ought to have been taxable as income under the Act and not the gross receipts/income

SHRI BHAICHAND PREMCHAND VADHAR MEHTA CHARITABLE TRUST,RAJKOT vs. THE ACIT, CPC, BANGLURU THROUGH ITO(EXEMPTION) WARD-1, RAJKOT

In the result, the appeal of the assessee is disposed off in above terms

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2014-15 Shri Bhaichand Premchand Acit, Cpc Bangaluru Vadhar Mehta Charitable Trust Vs Through It( Exemptions) 9, Vrundavan Society Ward-1, Rajkot. Nr. Roda-1, Rajkot. Pan : Aaets 5527 L

Charitable Trust Vs Through IT( Exemptions) 9, Vrundavan Society Ward-1, Rajkot. Nr. Roda-1, Rajkot. PAN : AAETS 5527 L (Applicant) (Responent) : Shri Bakul Ganatra, AR Assessee by Revenue by : Shri Shramdeep Sinha, CIT-DR सुनवाई क" तार"ख/Date of Hearing : 12/10/2022 घोषणा क" तार"ख /Date of Pronouncement: 19/10/2022 आदेश/O R D E R PER ANNAPURNA GUPTA

RAJKOT CITY CYBER SECURITY SOCIETY,RAJKOT vs. ITO WD 1(1)(1), RKT, RAJKOT

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

Bench: Dr. Arjun Lal Saini. & Shri Diesh Mohan Sinha

Trust had commenced its charitable activities, it subsequently applied for final approval as required under sub-clause (iii) of clause (ac) of sub-section (1) of Section 12A of the Income-tax Act on 27th September 2024. In response to this application, the Department issued various notices dated 17th January 2025 and 4th February 2025, calling for additional

CHINTAN DWARKADAS CHOTAI,JUNAGADH vs. DCIT/ACIT CIR 1(1), RKT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

income is declared to Rs.21,37,160/-. The flagged information indicated that the assessee had claimed donation u/s 80G of the Act of Rs.2,50,000/-(eligible amount of donation @ 50% was Rs. 1,12,482/-) to the charitable trust, i.e. All India Education Charitable Trust during the assessment year 2019-20. Accordingly, the AO was concluded that the assessee

BOLBALA CHARITABLE TRUST,RAJKOT vs. THE CIT (EXEMPTION), AHMEDABAD., AHMEDABAD

In the result, both the appeals filed by the assessee are allowed for statistical purpose

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 249&250/Rjt/2025 ("नधा"रणवष" / Assessment Year: (Na) (Hybrid Hearing) Bolbala Charitable Trust Vs. Cit(Exemption) Bolbala Sankul, 3, Milpara Main Room No. 609, Floor No. 6, Ayakar Road, Nr. Canal Road, Bhavan (Vejalpur), Prahalad Nagar, Rajkot - 360002 Road, Ahmedabad - 380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaatb3989K (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit(Dr) Date Of Hearing : 03/07/2025 Date Of Pronouncement : 08/07/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

charitable or religious trust or institution and Rule 17A(2) of the Income Tax Rules lists the documents which shall be attached or submitted with the application made in Form No. 10AB. To begin with, in the present application filed in Form 10AB, the applicant was requested to submit certain details/documents vide notices dated 23.07.2024. However, in response

BOLBALA CHARITABLE TRUST,RAJKOT vs. THE CIT (EXEMPTION), AHMEDABAD, AHMEDABAD

In the result, both the appeals filed by the assessee are allowed for statistical purpose

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 249&250/Rjt/2025 ("नधा"रणवष" / Assessment Year: (Na) (Hybrid Hearing) Bolbala Charitable Trust Vs. Cit(Exemption) Bolbala Sankul, 3, Milpara Main Room No. 609, Floor No. 6, Ayakar Road, Nr. Canal Road, Bhavan (Vejalpur), Prahalad Nagar, Rajkot - 360002 Road, Ahmedabad - 380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaatb3989K (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit(Dr) Date Of Hearing : 03/07/2025 Date Of Pronouncement : 08/07/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

charitable or religious trust or institution and Rule 17A(2) of the Income Tax Rules lists the documents which shall be attached or submitted with the application made in Form No. 10AB. To begin with, in the present application filed in Form 10AB, the applicant was requested to submit certain details/documents vide notices dated 23.07.2024. However, in response

SHRI SAJISAVAI MOXDHAM SEVA TRUST ,SAVARKUNDLA, DIST. AMRELI vs. THE CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 848 & 849/Rjt/2024 Shri Sajisavai Moxdham Seva Vs. The Cit (Exemption), Trust-Amreli, Savarkundla, Ahmedabad Amreli "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abbts9964K (अपीलाथ"/Appellant) (""यथ"/Respondent)

addition, trust does other social activities such as plants trees and takes care for the same, organise blood donation camps for helping needy people etc.. The assessee has applied for registration of the trust u/s. 12AB of the I.T. Act, 1961 on 03-02- 2024. Notice was issued to the assessee on 11-06-2024 asking the applicant