SHREEJI EDUCATION AND CHARITABLE TRUST,JAM KANDORANA vs. ITO EXEMPTION WD 1, RAJKOT, RAJKOT

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.107/Rjt/2025 ("नधा"रण वष" / Assessment Year: N.A.) Shreeji Education & Charitable Vs. Income Tax Officer (Exemption), Trust, Ta Jamkanodrana, At Ward-1, Rajkot, Race Course, Ring Jamkanodrana, Gujarat-360405 Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqts 3244 L (Appellant) (Respondent)

c) Spiritual- (1) To start knowledge centers for development of the spintual knowledge of the Supreme Element Spiritual knowledge without discrimination of any kind of religion or caste, the spirit of religion, the spirit of God, and higher spiritual knowledge in human beings and to realize the principle of 'Atma Atina, Bhat Bhai' and remove the religious superstition and ignorance

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) :

C Nr. Sacin Tower 100 FT Road, Anandnagar Prahladnagar Road, Ahmedabad-3800 015 (अपीलाथ"/Assessee) (""यथ"/Respondent) : "नधा"रती क" ओर से/Assessee by : Shri Kalpesh Doshi, ld.AR राज"व क" ओर से/Revenue by : Shri Sanjay Punglia CIT-DR सुनवाई क" तार"ख /Date of Hearing : 09/07/2025 घोषणा क" तार"ख /Date of Pronouncement : 22/07/2025 ORDER Per, Dr. Arjun

ACIT, CIR-1(1), RAJKOT, RAJKOT vs. SHRI RAJKOT DISTRICT CO OPERATIVE BANK LTD, RAJKOT

The appeal of the revenue is dismissed

Bench: Dr. Arjun Lal Saini. & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.188/Rjt/2024 िनधा"रणवष"/ Assessment Year: (2015-16) (Hybrid Hearing) Assistant Commissioner Of Income- Vs. Rajkot District Co-Operative Bank Tax, Circle-1 (1), Rajkot Limited Room No.502, Aayakar Bhawan, Jilla Bankbhavan, Kasturba Road, Race Course Ring Road, Rajkot- Opp: Chaudhary High School, 360001 Rajkot 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaar0564K (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr : 09/06 /2025 Date Of Hearing Date Of Pronouncement : 05/08 /2025

charitable purpose under section 11(1)(a), then assessee cannot claim depreciation on value of such assets. 7. That Ld. AR on behalf of the assessee has filed written submission on 18/02/2025. The details of claim of deduction made u/s36(1)(viii) by the Appellant are as under: Sr. Particulars Amount (in Rs.) 1. Claim made in the return

THE DCIT, (EXEMPTION) CIRCLE-2,, AHMEDABAD vs. GYANGANGA EDUCATION SOCIETY,, RAJKOT-GUJARAT

In the result the appeals filed by the Revenue are hereby dismissed

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumar

charitable trust registered under section 12A of the Income Tax Act, 1961 ("the Act" for short) and engaged in the activity of imparting education and running schools in the city of Rajkot. The assessee filed its return ITA No.15 & 16/RJT/2015 2 of income declaring income at Rs.NIL and claimed exemption under section 11 of the Act. The returns were selected

THE DCIT, (EXEMPTION) CIRCLE-2,, AHMEDABAD vs. GYANGANGA EDUCATION SOCIETY,, RAJKOT-GUJARAT

In the result the appeals filed by the Revenue are hereby dismissed

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumar

charitable trust registered under section 12A of the Income Tax Act, 1961 ("the Act" for short) and engaged in the activity of imparting education and running schools in the city of Rajkot. The assessee filed its return ITA No.15 & 16/RJT/2015 2 of income declaring income at Rs.NIL and claimed exemption under section 11 of the Act. The returns were selected

THE JT. CIT (EXEMPTIONS)(OSD), CIRCLE-2,, AHMEDABAD vs. GYANGANGA EDUCATION SOCIETY,, RAJKOT

In the result, the Revenue appeal is hereby dismissed

Bench: Us That This Similar Issue Is Being Adjudicated By The Very Same Bench Of This Tribunal In Assessee’S Own Case In Ita Nos. 15 & 16/Rjt/2015 Vide Order Dated 29.06.2022 Relating To The Assessment Years 2010-11 & 2011-12. Further This Order Has Been Followed In Ita No. 472, 1170 & 2316/Ahd/2017 For The Assessment Years 2012-13, 2013-14 & 2014-15 By Order Dated 31.08.2022. Now The Present Assessment Year Is 2015-16, Which Is Fully Covered By The Above Orders Of This Tribunal & Copy Of The Orders Are Also Placed On Record.

charitable trust registered under section 12A of the Income Tax Act, 1961 ("the Act" for short) and engaged in the activity of imparting education and running schools in the city of Rajkot. The assessee filed its return of income declaring income at Rs.NIL and claimed exemption under section 11 of the Act. The returns were selected for scrutiny assessment

SHREE BAUA BHAVIK MANDAL NANI TUMBDI,KUTCH vs. CIT(EXEMPTION), AHMEDABAD

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.367/Rjt/2023 Assessment Year: (Na) (Hybridhearing) Shree Baua Bhavik Mandal Vs. Cit(Exemption), Nani Tumbdi- Charitable Trust, Ahmedabad.

c) of Income Tax Act, 1961 is applicable to the assessee, whereas trust under consideration has started activities prior to commencement of the Income Tax Act, 1961.Second reason of rejection of application by the Commissioner of Income Tax(Exemption) was that the trust was created for particular community called “ Baua Nukh” family. In this regard, ld Counsel submitted that trust

SHRI VISHA OSWAL MAHAJAN KHAROI, BHACHAU - KUTCHH - GUJARAT.,BHACHAU-KUTCH-GUJARAT vs. THE CIT (EXEMPTION), AHMEDABAD, AHMEDABAD

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.325/Rjt/2023 "नधा"रणवष" / Assessment Year: (2022-23) (Hybrid Hearing) Shri Visha Oswal Mahajan Kharoi, Vs. Cit(Exemption), Room No: 609, 6Th Floor, Aaykar Bhachau – Kutch 370140 Bhuvan, (Vejalpur), 100 Feet Road, Anandnagar Prahladnagar Road, Ahmedabad 380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aapts3740J (Appellant) (Respondent) Appellant By : Shri Darshak Thakkar, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Sr. Dr Date Of Hearing : 02 / 06 /2025 Date Of Pronouncement : 09 / 07 /2025

1. Main area of charitable activities is Relief to Poor, Medical Relief and Education. In the Next 02 years trust is having plan to perform all these activities at large scale. 2. Trust has Registered under Bombay Public Trust Act, 1950 on 13/02/1962. Trust has applied for approval u/s 12AA for First time. Activities of trust has been commenced

JEEWANDEEP HEALTH EDUCATION CHERITABLE TRUST ,KODINAR vs. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No. 899/Rjt/2024 (िनधा"रण वष" / Assessment Year: (2022-23) (Hybrid Hearing) Jeewandeep Health Educa"On Vs. Cit (E), Ahmedabad Charitable Trust C/O Sloak Chavada 2/12 Rajnagar, Chorwadi Road Kodinar, Junagadh-362720, Gujarat India "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabtj2272Q (Appellant) (Respondent)

charitable trust. Also it has violated the provision of clause (ii) of sub-section (5) of section 80G of the act and hence the applicant is not entitled to get approval u/s. 80G (5) of the Income Tax Act therefore the present application filed in Form 10AB is liable to be rejected. Looking to the above facts, the present application

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

11 of the Act while as per the Revenue the claim of depreciation in the subsequent years therefore tantamounted to double deduction. The relevant findings of the A.O. at Para 3.2 of the order is as under: 3.2 In the case of a trust the income is not computed in normal commercial manner. The allowance of depreciation as further application

RAJKOT JILLA GAYATRI PARIVAR TRUST,,RAJKOT-GUJARAT vs. THE COMMR. OF INCOME TAX-1,, RAJKOT-GUJARAT

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No.52/Rjt/2016 ("नधा"रण वष"/Assessment Year : - ) Rajkot Jilla Gayatri Parivar The Commissioner Of बनाम/ Trust Income-Tax-I Vs. 7-Vashalinagar Rajkot Opp. Amrapali Cinema Raiya Road, Rajkot "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : None (Written Submission) ""यथ" क" ओर से/Respondent By: Shri Jitendra Kumar, Cit-Dr

C - Trib) 8.10 Right from 1936 the assessee has been carrying on its activities with the same intent and purpose pronounced by the father of nation and assessee was granted registration under section 10(23C)(iv) , section 12A and section 80(5) , therefore, assessee trust was entitled to recognition under section 80G(5) - vide Sevagram Ashram Pratishthan

SHRI SATYA KABIR SAHEB NI GADI,JAMNAGAR vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD, 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.129/Rjt/2025 िनधा"रणवष"/ Assessment Year: N.A. Shri Kabir Kirti Mandir Kashi The Commissioner Of Income बनाम Kabir Ashram Road Tax (Exemption) Kabir Para Road Vs. Anandnagar Outside Khambalia Gate Ahmedabad. Jamnagar. Pan : Aabts0260M (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By. : Shri Dushyant Maharshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr सुनवाई क" तारीख /Date Of Hearing : 09/06/2025 घोषणा क" तारीख /Date Of Pronouncement : 28/08/2025 Order Per, Dr. Arjun Lal Saini: Captioned Appeal Filed By The Assessee, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Exemption), Wherein The Commissioner Has Denied The Approval Under Section 80G(5)(Iii) Of The Income- Tax Act, 1961 (Hereinafter Referred To As 'The Act') & Rejected The Assessee’S Application Filed In Form No.10Ab For Approval In Clause (Iii) Of First Proviso To Section 80G(5) Of The Act. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows: “1. Hon. Cit(Exemption) Erred In Law As Well As On Facts In Rejecting The Registration U/S. 80G(5) By Contending That Major Activities Of Assessee Are Religious In Nature. Hon. Cit(Exemption) Has Not Appreciated The Facts That Although Having Some Of The Shri Kabir Kirti Mandir Kashi

section 80G(5) of the Income–tax Act, 1961. Therefore, ld. CIT(E ) again issued notice to the assessee to explain the objects of religious in nature. In response, the assessee submitted paper book before the learned Shri Kabir Kirti Mandir Kashi ITA No.129 /RJT/2025 3 CIT(E ) and stated that assessee trust is not created for performing religious activities

SHRI NANABHAI BHARVAD SEVA SAMAJ GUJRAT,RAJKOT vs. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

charitable trust, also it has violated the provision of clause(ii) of sub-section (5) of section 80G of the 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, u/s 80G(5)(iii) was rejected. 7. Aggrieved by the order

AMRELI MODH VANIK COMMUNITY PROPERTY,AMRELI vs. THE PR. 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 No.360/Rjt/2024 "नधा"रण वष"/ Assessment Year: 2024-25 Amreli Modh Vanik Principal Commissioner Of Community Property बनाम Income-Tax(Exemption), Nr. Rajkamal Chowk, Amreli- /Vs. Ahmedabad, 365 601 Room No.609, 6Th Floor, Ayakar Bhawan (Vejalpur), Nr. Sacin Tower 100 Ft Road, Anandnagar Prahladnagar Road, Ahmedabad-3800 015 "थायीलेखासं /.जीआइआरसं . / Pan/Gir No.: Aagta 8104 R (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia Cit-Dr

charitable activities according to the PTR. Amreli Modh Vanik Community Property 5 3 Self-certified copy of trust deed/Memorandum & The PTR is itself in English which is attached herewith for Articles of Association(MoA/AoA) in English, if your ready reference. original trust deed is not in English. 4 Please furnish audit reports of last 3 years (F.Ys 2019- Audit reports

GOHEL KELAVANI TRUST,RAJKOT vs. CIT EXEMPTIONS , 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./I.T.A. No.46/Rjt/2024 (िनधा"रण वष" / Assessment Year : -Na-) Gohel Kelavani Trust बनाम/ The Cit (Exemptions) 112, Aditya Centre, Rajkot Ahmedabad – 380 015 Vs. Rajkot – 360 001 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaatg 1452 C (अपीलाथ" /Appellant) .. (""थ" / Respondent) Assessee By : Shri Ashok Mehta, Ld.Ar Revenue By : Shri Sanjay Punglia, Ld. Cit(Dr) सुनवाई की तारीख / Date Of Hearing 17 /03/2025 घोषणा की तारीख /Date Of Pronouncement 7 /04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha: This Appeal By The Assessee Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Exemption), Ahmedabad [Hereinafter Referred To As “Cit(E)”], Dated 09/01/2024, Rejecting The Application For Registration Under Section 12Ab Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

C (अपीलाथ" /Appellant) .. (""थ" / Respondent) Assessee by : Shri Ashok Mehta, Ld.AR Revenue by : Shri Sanjay Punglia, Ld. CIT(DR) सुनवाई की तारीख / Date of Hearing 17 /03/2025 घोषणा की तारीख /Date of Pronouncement 7 /04/2025 आदेश / O R D E R PER DINESH MOHAN SINHA, JUDICIAL MEMBER: This appeal by the assessee is directed against the order passed

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

c) The notice u/s. 148(A) has been issued by a Non-Jurisdictional AO. 1. The appellant is a registered trust u/s 12A of the Act and has been carrying out charitable activities since past many years. It is submitted that, the jurisdiction of the appellant lies with ITO Exemption Ward - 1, Rajkot. In order to substantiate our claim

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

c) The notice u/s. 148(A) has been issued by a Non-Jurisdictional AO. 1. The appellant is a registered trust u/s 12A of the Act and has been carrying out charitable activities since past many years. It is submitted that, the jurisdiction of the appellant lies with ITO Exemption Ward - 1, Rajkot. In order to substantiate our claim

SATVARA GNATI SAMAJ SEVA MANDAL - MORBI,MORBI vs. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), RAJKOT

The appeal of the assessee is allowed for statistical purpose

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 43 & 44/Rjt/2024 (Assessment Year: Na) (Hybrid Hearing) Satvara Gnati Samaj Seva Mandal. Vs. Cit(Exemption), Ahmedabad. Shree Ashapura Nivas, Sundarvan Society, Shakat Sanala, Morbi. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abbts5898L (अपीलाथ"/Appellant) (""यथ"/Respondent)

11 of the Act. Even some courts had held that in case of composite trust/institution, i.e. charitable cum religious, the provision of section 13(1)(b) of the Act is not applicable. However, the said controversy was resolved by the Hon’ble Supreme Court in the case of CIT Vs. Dawoodi Bohara Jamat (43 Taxmann.com 243), wherein