SAURASHTRA RACHNATMAK SAMITI SEVA TRUST,RAJKOT, GUJARAT vs. ADIT, CPC, BENGALURU, JURISDICTION - RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No.124/Rjt/2024 Assessment Year: (2019-20) (Hybrid Hearing) Saurashtra Rachnatmak Samiti Seva Vs. Adit, Trust. Cpc, Bengaluru. Rashtriya Shala Compound, Jurisdiction Rajkot. Rajkot- 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaats9227M (Appellant) (Respondent)

charitable trust duly registered under the provisions of section 12A of the Income Tax Act, 1961.The assessee filed an appeal before the ld. CIT(A) against the intimation u/s 143(1) of the Act. The assessee-trust stated before us that it had received a corpus donation of Rs. 3,00,00,000/-during the course of assessment year under

INDIAN RED CROSS SOCIETY GIR SOMNATH DISTRICT BRANCH,SOMNATH vs. THE CIT (EXEMPTION), 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. 180 & 181/Rjt/2024 ("नधा"रणवष" / Assessment Year: (Na) Indian Red Cross Society Gir Somnath Cit(Exemption) Vs. District Branch Room No. 609, Floor No. 6, Block No.4, Divya Apartment, Opp. Sbi Ayakar Bhavan (Vejalpur), 100Ft Bank, 80Ft Road, Veraval, Gir-Somnath, Road, Ahmedabad - 380015 Gujarat-362266 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabai3231R (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit(Dr) Date Of Hearing : 31/07/2025 Date Of Pronouncement : 29/10/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

section 12A of the Act for registration of a charitable or religious trust on institution and stipulates. A notice was issued to the applicant/assessee on 13/04/2023 and sent through ITBA with a request to furnish detailed note on the activities actually carried out by the trust as well as certain details/documents as mentioned therein. response to the notice, the applicant/assessee

INDIAN RED CROSS SOCIETY GIR SOMNATH DISTRICT BRANCH,GIR SOMNATH vs. THE CIT (EXEMPTION), 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. 180 & 181/Rjt/2024 ("नधा"रणवष" / Assessment Year: (Na) Indian Red Cross Society Gir Somnath Cit(Exemption) Vs. District Branch Room No. 609, Floor No. 6, Block No.4, Divya Apartment, Opp. Sbi Ayakar Bhavan (Vejalpur), 100Ft Bank, 80Ft Road, Veraval, Gir-Somnath, Road, Ahmedabad - 380015 Gujarat-362266 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabai3231R (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit(Dr) Date Of Hearing : 31/07/2025 Date Of Pronouncement : 29/10/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

section 12A of the Act for registration of a charitable or religious trust on institution and stipulates. A notice was issued to the applicant/assessee on 13/04/2023 and sent through ITBA with a request to furnish detailed note on the activities actually carried out by the trust as well as certain details/documents as mentioned therein. response to the notice, the applicant/assessee

SHREE GAMARA SAMAJIK SEVA MANDAL,,SURENDRANAGAR vs. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS),, AHMEDABAD

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

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2014-15

45(II) ITCL 57 Chennai ITAT. 4. Where original trust deed as well as copy thereof along with income and expenditure account is already furnished. The rejection of 12A application will not approve. 27 SOT 423 Delhi ITAT. . 5. Even if there is some suspicion regarding income as well as resources rejection was not approve

ASSOCIATION OF CONSULTING CIVIL ENGINEERS,RAJKOT vs. INCOME TAX OFFICER GUJ-W-201-1, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं/.Ita No.731/Rjt/2024 िनधा"रणवष"/ Assessment Year: (2023-24) (Hybrid Hearing)

45] For the judicial pronouncement sited before Ld. CIT-A, please refer Page No: 39-42, 46 & 50-56 of the Paper Book. The Learned Assessing Officer (AO), however, treated the surplus arising from contributions, sponsorship and interest income as taxable at the MMR of 42.744%. This classification disregards the principle of mutuality, under which surplus income from mutual dealings

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

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