ANANDABAVA SEVA SANSTHA GAUSHALA TRUST JAMNAGAR,JAMNAGAR vs. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 31/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2024-25) (Hybrid Hearing) Anandbava Seva Sanstha Gaushala Trust, The Pr. Commissioner Of Income Vs. Gopal Bhuvan No, Anandbava Chakalo, Tax (E), Jamnagar 361001 Ahmedabad 380015 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaata2817K (Appellant) (Respondent) Appellant By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Sr. (Dr) Date Of Hearing : 22/07/2025 Date Of Pronouncement : 21/10/2025

1)(b) of the Act would be the Act. The relevant observations of the Hon'ble Supreme Court are as under: - Anandabava Seva Sanstha Gaushala Trust attracted to the assessee trust and therefore, it would be eligible to claim exemption under section 11 of "(i) that determination of the nature of the trust as wholly religious or wholly charitable

SHREE PARJIYA BRAHMAN ABHYUDAY MANDAL,KUTCH vs. CIT(EXEMPTION), AHMEDABAD

In the result, no question of law arises

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.327/Rjt/2023 ("नधा"रण वष" / Assessment Year: (Na) (Hybrid Hearing) Shree Parjiya Brahman Vs. Cit(Exemption) Abhyuday Mandal Ahmedabad Adesarr Rapar, Kutch Rapar, Gujarat 370155 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abeas2267F (Assessee) (Respondent) Assessee By : Shri Kalpesh Doshi, Ar Respondent By : Shri Sanjay Punglia, Cit.Dr Date Of Hearing : 08/10/2024 Date Of Pronouncement : 06/01/2025 आदेश / O R D E R

Trust with charitable objects, which existed for the benefit of a particular religious community qualified as charitable entity serving the public at large and this was sufficient for grant of registration under section 12A of the Act, and the provisions of section 13(1

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)

12A of the Act Shreeji Education and Charitable Trust w.e.f. 01.04.2022. This registration so granted by ld.CIT(E) is still continued. 14. At this juncture, it is appropriate to go through the provisions of section 80G of the Act, which is applicable to the assessee-trust under consideration, which are reproduced below for ready reference: “Deduction in respect of donations

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) :

section 80G(5) of the Act to have only charitable objects. Therefore, objects of the trust themselves cannot be wholly and substantially religious in nature. The objects of the trust should be wholly or substantially charitable in nature. Therefor Ld. CIT-DR submitted that assessee’s application Shri Umiya Mataji Ishver Ramji Annakshetra Trust 8 for approval u/s.80G

SHRI RAJKOT VISHASHRIMALI JAIN SAMAJ ,RAJKOT vs. THE ITO, EXEMPTION WARD-1, RAJKOT, RAJKOT

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

1) of the Act. 4. That the appellant craves for leave to add, amend and/or modify the grounds of appeal.” 3. The brief facts of the case are that the assessee is a public charitable trust duly registered under the provisions of Mumbai Trust Act, 1950 and Section 12A

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.

section 12A(1)(ac)(vi) for the period commencing from assessment year (AY) 2022-23 to AY 2024-25. From perusal of objects of the assessee-trust, it was observed by ld. CIT(E ) that following objects, which are otherwise charitable

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”).

section 12A(1)(ac) of the Act. 5.1. The Ld.Authorized Representative (AR) for the assessee submitted that, instead of verifying the genuineness of the trust or examining its charitable

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

In the result, the appeal filed by the assessee is treated as allowed\nfor statistical purposes in above terms

charitable trust, also it has\nviolated the provision of clause(ii) of sub-section (5) of section 80G of the Act\nand hence the assessee is not entitled to get approval u/s. 80G(5) of the Income\nTax Act, therefore the assessee`s application filed in Form 10AB, u/s 80G(5)(iii)\nwas rejected.\n7. Aggrieved by the order

SHRI JAIN SWETAMBER MURTIPUJAK TAPGACHCHH SANGHA,DHORAJI, DIST. RAJKOT vs. THE NFAC (APPEALS) DELHI, DELHI

In the result the appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

1) of Rs.2,63,026/-as claimed 5.2 In the written submission the A.R of the appellant stated that the appellant was registered u/s 12A. 5.3.1 As per section 12A(b) one of the condition for applicability of sections 11 and 12 is - where the total income of the trust or institution as computed underthis Act without giving effect

SHREE LOLADI MATAJI MADH TRUST,GANDHIDHAM vs. 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./I.T.A. No.836/Rjt/2024 (िनधा"रण वष" / Assessment Year : -Na-) Shree Loladi Mataji Madh बनाम/ The Pr.Cit (Exemptions) Trust Ahmedabad – 380 015 Vs. Shinay, Vagamshi Faliya Shinay Gandhidham – 370 205 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aayts 3998 R (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri Mehul Ranpura, Ld.Ar Revenue By : Shri Sanjay Punglia, Ld. Cit(Dr) सुनवाई की तारीख / Date Of Hearing 12 /02/2025 घोषणा की तारीख /Date Of Pronouncement 05/05/2025 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 02/09/2024, Rejecting The Application For Registration Under Section 12Ab Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

1) of section 12A of the Income Tax Act for registration of a charitable or religious trust or institution and Rule

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)

charitable organizations. Due to absence of registration, tax liability is fastened even though they may otherwise be eligible for exemption and fulfil other substantive conditions. However, the power of condonation of delay in seeking registration was not available. 8.3 In order to provide relief to such trusts and remove hardship in genuine cases, section 12A of the Income

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)

Charitable Trust (supra) dealt with only the issue/terminology of “whichever is earlier” which is applicable to new trust which have created recently, and it does not deal with condonation of delay in case of old trust who made the application before ld CIT(E ) very late, that is, the issue mention in clause (iii) of 3rd proviso of section

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

12A(1) (ac)(iii) of the Income-tax Act, 1961 by not providing proper opportunity of being heard to the appellant trust. 3. Ld. CIT(E) erred on facts as also in law in holding that the appellant does not have valid order of registration under section 12A/12AB of the Act by stating that the appellant trust is working

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 Trust or sub-clause (v) [or item (B) of sub-clause (vi)] of clause (ac) of sub-section (1) of section 12A

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 Trust or sub-clause (v) [or item (B) of sub-clause (vi)] of clause (ac) of sub-section (1) of section 12A

ADHYAKSHYA LOK MELA AMLIKARAN SAMMITTEE,RAJKOT vs. INCOME TAX OFFICER, WARD-1(2),, RAJKOT

Appeal of the assessee is partly allowed for the statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy, आयकर अपील सं./Ita Nos. 424 & 425/Rjt/2018 वष"/Asstt. Years: 2009-2010 & 2010-2011 िनधा"रण वष" िनधा"रण िनधा"रण िनधा"रण वष" वष" Adhyakshya Lok Mela Amlikaran Ito Sammittee Vs. Ward-1(2), A.D. Vyas & Co., Kotecha Nagar Rajkot Main Road, Opp. Kotecha Girls High School, Rajkot-360001 Pan: Aabaa0922F Assessee By : Shri D. M. Rindani, A.R Revenue By : Shri Shramdeep Sinha, D.R सुनवाई क" तारीख/Date Of Hearing : 24/04/2023 घोषणा क" तारीख /Date Of Pronouncement: 17/05/2023 आदेश/O R D E R आदेश आदेश आदेश Per Waseem Ahmed: The Captioned Appeals Have Been Filed At The Instance Of The Assessee Against The Common Orders Passed Under Section 263 Of The Act By The Learned Commissioner Of Income Tax Rajkot Dated 24/03/2014 Arising In The Matter Of Assessment Order Passed Under S. 143(3) Of The Income Tax Act, 1961 (Here-In- After Referred To As "The Act") Relevant To The Assessment Years 2009-10 & 2010- 11. First, We Take Up Ita 424/Rjt/2018, An Appeal By The Assessee For The Ay 2009-10 2. The Assessee Has Raised The Following Grounds Of Appeal: “Ground No 1 Order Of The Learned Cit 1 Rajkot Reopening The Assessment U/S 263 Is Totally Bad On Facts As Well On Law. Learned Cit Ought To Have Considered The Fact That The Assessee Is Already Assessed U/S 143(3) By Ito 1(2) Rajkot.

12A(2) of the Act brought in the statute effective from 1 October 2014 by the Finance ( Act No. 2) 2014 can be applied for the assessment year under consideration? ii. If yes, then applicability for allowing the exemption under section 11(1)(a) of the Act is limited to the issue of income enhanced by ₹1

ADHYAKSHYA LOK MELA AMLIKARAN SAMMITTEE,RAJKOT vs. INCOME TAX OFFICER, WARD-1(2),, RAJKOT

Appeal of the assessee is partly allowed for the statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy, आयकर अपील सं./Ita Nos. 424 & 425/Rjt/2018 वष"/Asstt. Years: 2009-2010 & 2010-2011 िनधा"रण वष" िनधा"रण िनधा"रण िनधा"रण वष" वष" Adhyakshya Lok Mela Amlikaran Ito Sammittee Vs. Ward-1(2), A.D. Vyas & Co., Kotecha Nagar Rajkot Main Road, Opp. Kotecha Girls High School, Rajkot-360001 Pan: Aabaa0922F Assessee By : Shri D. M. Rindani, A.R Revenue By : Shri Shramdeep Sinha, D.R सुनवाई क" तारीख/Date Of Hearing : 24/04/2023 घोषणा क" तारीख /Date Of Pronouncement: 17/05/2023 आदेश/O R D E R आदेश आदेश आदेश Per Waseem Ahmed: The Captioned Appeals Have Been Filed At The Instance Of The Assessee Against The Common Orders Passed Under Section 263 Of The Act By The Learned Commissioner Of Income Tax Rajkot Dated 24/03/2014 Arising In The Matter Of Assessment Order Passed Under S. 143(3) Of The Income Tax Act, 1961 (Here-In- After Referred To As "The Act") Relevant To The Assessment Years 2009-10 & 2010- 11. First, We Take Up Ita 424/Rjt/2018, An Appeal By The Assessee For The Ay 2009-10 2. The Assessee Has Raised The Following Grounds Of Appeal: “Ground No 1 Order Of The Learned Cit 1 Rajkot Reopening The Assessment U/S 263 Is Totally Bad On Facts As Well On Law. Learned Cit Ought To Have Considered The Fact That The Assessee Is Already Assessed U/S 143(3) By Ito 1(2) Rajkot.

12A(2) of the Act brought in the statute effective from 1 October 2014 by the Finance ( Act No. 2) 2014 can be applied for the assessment year under consideration? ii. If yes, then applicability for allowing the exemption under section 11(1)(a) of the Act is limited to the issue of income enhanced by ₹1

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