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)

trust is registered under section 12AA of the Act for the past 40 years and the said registration is still in existence. It is also not the case of the Revenue that the assessee has ceased to be a religious or charitable

SHREE NANI KHAKHAR RAJPUT KSHATRIYA SAMAJ SEVA TRUST,KACHCHH vs. CIT (EXEMPTION), RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.40/Rjt/2025 िनधा"रणवष" / Assessment Year: N.A. Shree Nani Khakhar Rajput,Kshatriya The Cit(Exemption) बनाम Samaj Seva Trust. Ahmedabad Vs. Nani Khakhar, Tal Mandvi- Kachchh Gujarat-370001 Pan :Aaxts3860K (अपीलाथ"/Appellant) : (""यथ"/Respondent) िनधा"रत क"ओर से/Assessee By : Ms. Chaunauti H. Dholakia, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr सुनवाई क" तारीख /Date Of Hearing : 09/07/2025 घोषणाक"तारीख /Date Of Pronouncement : 18/07/2025 Order Per Dr. Arjun Lal Saini:

Trust ITA No. 40-Rjt2025 5 be charitable in nature but these objects, which are charitable in nature, are confined to the benefit of Rajput Kshatriya Samaj Community. Therefore Ld. D.R. for the Revenue submitted that it is a specified violation under clause (d) below explanation 1 of Section

JAIN SANGHATANA FOUNDATION-JAMNAGAR,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 359/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2025-26) Jain Sanghatana Foundation -Jamnagar, Cit (Exemption), Ahmedabad Vs. 15 Sidhbath Complex, K V Road, Aayakar Bhawan, Anandnagar- Jamnagar - 361001 Prahladnagar Road, Ahmedabad - 380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aajaj8198C (Appellant) (Respondent) Appellant By : Shri Sagar Shah, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Sr. (Dr) Date Of Hearing : 07/07/2025 Date Of Pronouncement : 03/10/2025

section 80G(5)(iii) Moreover, the show cause notice was issued of the act dated 20.12.2024 (copy of the same enclosed herewith from Page No. 33 to 34) stating that Jain Sangathan Foundation one of the objects of the trust is religious in nature and against the said show cause notice the trust have filed response dated 24.12.2024 mentioning that

MEENA SAMAJ SEVA SAMITI TRUST,GANDHIDHAM vs. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

charitable purpose, subject to concession granted under Sec. 80G(5B) of the Act. Therefore, Ld.CIT(E) has denied the approval under section 80G(5)(iii) of the Income-tax Act, 1961 (hereinafter referred to as “the Act') and also cancelled the provisional approval of the assessee-trust. 6. Aggrieved by the order of Ld.CIT(E), assessee is in appeal before

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

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

ANKUL CONSTRUCTION CO.,RAJKOT vs. THE ASSIT. DIRECTOR OF INCOME TAX , CPC BENGLURU/ITO WD-1(2)(1), RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 484/Rjt/2024 Assessment Year: (2020-21) (Hybrid Hearing) Anukul Constriction Co. Vs. Asstt. Director Of Income 901, Aalap-B, Opp. Shastri Ground, Tax, Cpc Bangaluru / Ito Limda Chowk, Ward 1(2)(1), Rajkot – 360001 Aayakar Bhavan, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfa2385E (Appellant) (Respondent) Appellant By : Shri Jay Kathrani, Ld. A.R. Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 04/02/2025 Date Of Pronouncement : 17/02/2025

40(a)(ia): 1. CPC has made addition by way of disallowance u/s 40a(ia) without considering fact that non obstacle clause of section 40a(la) are not applicable to Purchase / Direct Expenses allowed as deduction u/s 28(i). 2. Assessee is engaged in the business of Civil Construction as Government Contractor. Sub Contract Expenses are Purchase of Service directly

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

charitable purpose, the prudence of the businessman himself in making the interest-free advance is critically relevant and possibly decisive for a finding of business expediency, particularly if and when the recipient of interest free funds is also taxed at maximum rate. The facts of the case, in our view are also thus squarely covered by the Supreme Court decisions

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

charitable purpose, the prudence of the businessman himself in making the interest-free advance is critically relevant and possibly decisive for a finding of business expediency, particularly if and when the recipient of interest free funds is also taxed at maximum rate. The facts of the case, in our view are also thus squarely covered by the Supreme Court decisions

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

charitable purpose, the prudence of the businessman himself in making the interest-free advance is critically relevant and possibly decisive for a finding of business expediency, particularly if and when the recipient of interest free funds is also taxed at maximum rate. The facts of the case, in our view are also thus squarely covered by the Supreme Court decisions

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM-KUTCH vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM-KUTCH

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

charitable purpose, the prudence of the businessman himself in making the interest-free advance is critically relevant and possibly decisive for a finding of business expediency, particularly if and when the recipient of interest free funds is also taxed at maximum rate. The facts of the case, in our view are also thus squarely covered by the Supreme Court decisions

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

charitable purpose, the prudence of the businessman himself in making the interest-free advance is critically relevant and possibly decisive for a finding of business expediency, particularly if and when the recipient of interest free funds is also taxed at maximum rate. The facts of the case, in our view are also thus squarely covered by the Supreme Court decisions