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

charitable trusts to be eligible to exemption u/s 11 of the Act, In the case of Ahmedabad Rana Caste Association vs Commissioner of Income Tax (1971) 82 ITR 704(SC). The Hon’ble apex court held that such trusts though benefitting only a section of the society, could still be termed as for the benefit of public at large

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 SWAMI VIVEKANAND TRUST,ADIPUR vs. THE DCIT (CPC) , BANGALORE

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

charitable Trust under section 12A of the Income Tax Act. For the Assessment Year 2014-15, the assessee filed its Return of Income on 30.01.2015. The assessee received Audit Report in Form No. 10B on 24.04.2014 and physically filed the same before the Assessing Officer namely ITO, Gandhidham on 20.05.2014. Invoking section 139(1) of the Act, Centralized Processing Centre

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.

Trust Vs. PCIT(E) AY : 2015-16 2014, is that assessees’ claiming exemption of their income u/s. 10(23C)(vi) of the Act or Section 11 of the Act are debarred from claiming exemption of such income under any other provision of Section 10 of the Act. What has been introduced by virtue of amendment made by Finance

SHRI KAKA VALLABHJI GRUHVALLABHIYA TRUST,PORBANDAR vs. 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 Sinhaआयकरअपीलसं./Ita No.123/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2025-26) Shri Kaka Vallabhji Gruhvallabhya Trust Vs. Cit(Exemption), Room No.609, 6Th Floor, Aayakar Shree Chandragopalji Govedhaneshji Maharaj, Vekurdi Plot, Bhavan, Nr. Sachin Tower, 100Ft Porbandar - 360575 Road, Anandnagar-Prahladnagar Road, Ahmedabad-380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahts6624H (Appellant) (Respondent) Appellant By : Shri Viral Vajani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit(Dr) : 24/07/2025 Date Of Hearing Date Of Pronouncement : 16/10/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

section 80G(5) of the Act is rejected and your provisional approval also stands cancelled. 6. That the assessee has challenge the validity of order dated 23.12.2024 of the Ld. CIT(E) by filing the appeal before us. 7. During the course of hearing, Ld. AR submitted that trust is a charitable trust. There is no object to carry

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)

charitable trust duly registered under the provisions of Mumbai Trust Act, 1950 and Section 12A of the Income Tax Act, 1960. For the year under consideration, the assessee e-filed its return of income on 10-02-2021 declaring total income and expenditure as under:- 2. For the assessment year under consideration the appellant e-filed its return of income

SEASONS SQUARE CHARITABLE TRUST,,RAJKOT vs. THE PR. COMMISSIONER OF INCOME TAX (EXEMPTIONS), , AHMEDABAD

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

18-09-2017 & 28-11-2017, in proceedings under section 12AA & 80G (5) of the Income Tax Act, 1961; in short “the Act”. I.T.A Nos. 402/Rjt/2017 & 35/Rjt/2018 Page No. 2 Seasons Square Charitable Trust

SEASONS SQUARE CHARITABLE TRUST,,RAJKOT vs. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), , AHMEDABAD

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

18-09-2017 & 28-11-2017, in proceedings under section 12AA & 80G (5) of the Income Tax Act, 1961; in short “the Act”. I.T.A Nos. 402/Rjt/2017 & 35/Rjt/2018 Page No. 2 Seasons Square Charitable Trust

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

MORBI PLOT JAIN TAP GACHH SANGH,,MORBI vs. ASSTT. COMMR. OF INCOME TAX(CPC),, BANGLORE

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

charitable Trust had been issued the registration certificate under Section 12A of the Act, 1961. A practical way needs to be found out in such type of litigation. Let this entire exercise be undertaken at the earliest and be completed within a period of four weeks from the date of receipt of the order by the department. 18

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)

section of public and the kind attention is drawn towards judgment delivered by the Gujarat High Court in case of Hiralal Bahgwati (2000) 246 ITR 188 and Ahmedabad Rana Caste Association 140 ITR 1 (SC). The assessee has placed on record the documentary evidences such as trust deed in Gujarati and English version also, copy of audited accounts

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

section of public and the kind attention is drawn towards judgment delivered by the Gujarat High Court in case of Hiralal Bahgwati (2000) 246 ITR 188 and Ahmedabad Rana Caste Association 140 ITR 1 (SC). The assessee has placed on record the documentary evidences such as trust deed in Gujarati and English version also, copy of audited accounts

SHREE MADHAPAR JAIN SAMAJ,MADHAPAR vs. CIT(EXEMPTION), AHMEDABAD

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.218/Rjt/2024 "नधा"रणवष"/ Assessment Year: Na Shree Madhapar Jain Samaj Cit (Exemption) बनाम Shri Aayambil Shala Junavas Ahmedabad Madhapar, Bhuj, Gujarat-370020 Vs. Pan : Aayts4000N (अपीलाथ"/Appellant) (""यथ"/Respondent) :

Section 12A(1)(ac)(iii) (hereinafter referred to as “the Act”) and provisional registration was also cancelled. 2. The grounds of appeal raised by the assessee are as under: “1. The Learned CIT (Exemption) has erred in law as well as on fact in framing opinion about the genuineness of the activities of the trust or institutions. Therefore, the impugned

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

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 in the year of creation

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

Appeals of the assessee are allowed for\nstatistical purposes

charitable activities at the time of obtaining\nProvisional registration, and not for those trust/institutions which have already started\ncharitable activities before obtaining Provisional Registration. We derive the strength from\nthe Speech of Hon'ble Finance Minister and the Memorandum of Finance Bill 2020.\n11.3 Therefore, in these facts and circumstances of the case, we hold that the Assessee Trust\nhad

SHRI SHARDAGRAM ALUMNI EDUCATION AND CHARITABLE TRUST,RAJKOT vs. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

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

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

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.

18. We have heard the rival contentions of both the parties and perused the materials available on record. The facts of the case are not in dispute which have been elaborated in the preceding paragraph, therefore for the sake of brevity and convenience, we are not inclined to repeat the same. From the foregoing discussion, the following issues arise

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.

18. We have heard the rival contentions of both the parties and perused the materials available on record. The facts of the case are not in dispute which have been elaborated in the preceding paragraph, therefore for the sake of brevity and convenience, we are not inclined to repeat the same. From the foregoing discussion, the following issues arise

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

Section 13(1)(b) of the Act, is not applicable to the assessee-trust. For that Ld. Counsel took us through the page-16 of paper book wherein registration certificate issued by Charity Commissioner Bombay is placed in the paper book pages 18, 19 and 22. The Ld. Counsel also submitted the undertaking made by the trustee, which is placed