LIONS UMRA PIPLOD EDUCATION SOCIETY,SURAT vs. A.O. CIRCLE-2, EXEPTION, , AHMEDABAD

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Hearing In Virtual Court) Lions Umra Piplod Education Society, The Assessing Officer, Opp. Lake View Garden, C/O. Circle-2, Exemption, Vs. Shardayatan School, Piplod, Surat- Ahmedabad. 395007, Gujarat. Pan : Aaatl1289Q Appellant Respondednt

trust, registration under section 12A of the Act was substantially satisfied condition for availing benefit of exemption as a charitable could not be 13 ITA No. 197/SRT/2021/AY.2017-18 Lions Umra Piplod Education Society denied exemption, the assessee merely on a bar of limitation in filing Audit Report in Form 10B. (emphasis added by us) 15. Considering the aforesaid factual and legal

SINDHU SEVA SAMITI,SURAT vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD

In the result, both the appeals are allowed for statistical purposes in above terms

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.214/Srt/2023 (Physical Hearing) Mar Baselius Orthodox Syrian Church, Vs. The Cit(Exemption), Ranchhod Nagar, Opp. Magdalla Port Colony, Ahmedabad Dumas Road, Magdalla B.O., Magdalla, Surat – 395007. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaatm3808N (Appellant) (Respondent) आयकर अपील सं./Ita No.265/Srt/2023 (Physical Hearing) Sindhu Seva Samiti, Vs. The Cit(Exemption), Tp No.3 Fp 53, Anand Mahal Road, Ahmedabad Near Sneh Sankul Wadi, Adajan Choryasi, Surat – 395009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabts3067J (Appellant) (Respondent)

charitable and religious trust which does not benefit any specific religious community and therefore, it cannot be held that Section 13(1)(b) of the Act would be attracted to the respondent-trust and thereby, it would be eligible to claim exemption under Section 11 of the Act.” 10

MAR BASELIUS ORTHODOX SYRIAN CHURCH,SURAT vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD

In the result, both the appeals are allowed for statistical purposes in above terms

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.214/Srt/2023 (Physical Hearing) Mar Baselius Orthodox Syrian Church, Vs. The Cit(Exemption), Ranchhod Nagar, Opp. Magdalla Port Colony, Ahmedabad Dumas Road, Magdalla B.O., Magdalla, Surat – 395007. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaatm3808N (Appellant) (Respondent) आयकर अपील सं./Ita No.265/Srt/2023 (Physical Hearing) Sindhu Seva Samiti, Vs. The Cit(Exemption), Tp No.3 Fp 53, Anand Mahal Road, Ahmedabad Near Sneh Sankul Wadi, Adajan Choryasi, Surat – 395009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabts3067J (Appellant) (Respondent)

charitable and religious trust which does not benefit any specific religious community and therefore, it cannot be held that Section 13(1)(b) of the Act would be attracted to the respondent-trust and thereby, it would be eligible to claim exemption under Section 11 of the Act.” 10

SHRI RAM EDUCATION & GRAMINVIKAS CHARITABLE TRUST,VALSAD vs. INCOME TAX OFFICER ( EXEMPTION WARD), SURAT

In the result, this appeal of the assessee is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainishri Ram Education & I.T.O., (Exemption Ward) Graminvikas Charitable Trust, Aayakar Bhavan, Vs. Jauagauri Park, Hathikhana, Majura Gate, Dharampur, Surat. Valsad-396050. Pan No. Aalts 324 F Appellant/ Assessee Respondent/ Revenue

section 12A. 14. We have considered the rival contentions of both the parties and have gone through the orders of authorities below carefully. The 10 Shri Ram Education & Graminvikas Charitable Trust

SHREE PARISHRAM EDUCATION & MEDICAL CHARITABLE TRUST,,VADODARA vs. THE PR. CIT(CENTRAL),, SURAT

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No. 610/Ahd/2016/Srt िनधा"रण वष"/Assessment Year : Shree Parishram Education & Vs. Pr. Commissioner Of Medical Charitable Trust, Income-Tax (Central), At Bakrol, Near Madhav Nagar, Surat. Ajwa-Nimeta Road, Tal. Waghodia, Dist. Vadodara-390010 Pan: Aaatp9715H अपीलाथ" Appellant ""यथ"/Respondent

Charitable Trust I.T.A. No.610/Ahd/2016 Page 3 of 15 3. Brief facts are that the assessee is a public trust which has got approval under section 10

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, , VAPI vs. M/S MAHAVIR JAIN CHARITABLE TRUST, VALSAD

In the result, the grounds of Revenue’s appeal are dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.208/Srt/2023 (Ay 2018-19) (Hearing In Virtual Court) Deputy Commissioner Of M/S Mahavir Jain Income-Tax, Central Circle-Vapi, Charitable Trust, 410/411, Vs 9Th Floor, Fortune Square Ii, Amar Chambers, Station Daman Road, Chala, Vapi- Road, Opp. Lal School, 396191 Valsad-396001 Pan No. Aamts 6784 K अपीलाथ"/Appellant ""थ" /Respondent

10 Mahavir Jain Charitable Trust purchase of property for set up of its new school and payment of huge unaccounted money of Rs.5.60 crores for that purpose. The area of land of land is clearly mentioned of such incriminating seized material. Before Ld. CIT(A) the assessee took the plea that it was merely an estimation fact or proposal

STAR EDUCATION TRUST,SURAT vs. CIT(EXEMPTION), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.539/Srt/2019 "नधा"रणवष"/Assessment Year: (2019-20) (Physical Court Hearing) The Star Education Trust, Vs. The Cit(Exemption), 9A, Ratnanilam Apartment, Piplod, Ahmedabad. Surat-395009. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabts2856F

charitable trust registered with Assistant Charity Commissioner, Surat dated 25.03.1998. The trust is carrying out educational activities through its institution namely, Tiny Star Higher Secondary School at Rajkot. 4. Learned CIT(E ) noted that as per second proviso of section 10

JAYSHRI GOPALLAL MAHARAJSHRINI SURAT SRUSTI TRUST,SURAT vs. ITO, EXEMPTION WARD, SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

charitable trust registered under section 12A of the Act. An intimation was issued by the CPC under section 143(1) of the Act, in which the amount claimed by the assessee as application of income and accumulation of income was disallowed and gross receipts of the assessee trust were taxed in the hands of the assessee. The reason for such

NAVBHARAT CHARITABLE TRUST,BHARUCH vs. INCOME TAX OFFICER, WARD - 1, , BHARUCH

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

Bench: Shri Pawan Singhita No. 383, 384 & 385/Srt/2022 (Assessment Years: 2017-18, 2018-19 & 2019-20) (Hearing In Virtual Court) Navbharat Charitable Trust, I.T.O., 0, Rajpardi, Jhagadia, Ward-1, Vs. Bharuch. Bharuch. Pan No. Aactn 0979 K Appellant/ Assessee Respondent/ Revenue

trust whereas Finance Act 2022 clarified by amending provisions of section 13(10) that in case of denial of exemption to a charitable

NAVBHARAT CHARITABLE TRUST,BHARUCH vs. INCOME TAX OFFICER, WARD - 1, , BHARUCH

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

Bench: Shri Pawan Singhita No. 383, 384 & 385/Srt/2022 (Assessment Years: 2017-18, 2018-19 & 2019-20) (Hearing In Virtual Court) Navbharat Charitable Trust, I.T.O., 0, Rajpardi, Jhagadia, Ward-1, Vs. Bharuch. Bharuch. Pan No. Aactn 0979 K Appellant/ Assessee Respondent/ Revenue

trust whereas Finance Act 2022 clarified by amending provisions of section 13(10) that in case of denial of exemption to a charitable

NAVBHARAT CHARITABLE TRUST,BHARUCH vs. INCOME TAX OFFICER, WARD - 1, , BHARUCH

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

Bench: Shri Pawan Singhita No. 383, 384 & 385/Srt/2022 (Assessment Years: 2017-18, 2018-19 & 2019-20) (Hearing In Virtual Court) Navbharat Charitable Trust, I.T.O., 0, Rajpardi, Jhagadia, Ward-1, Vs. Bharuch. Bharuch. Pan No. Aactn 0979 K Appellant/ Assessee Respondent/ Revenue

trust whereas Finance Act 2022 clarified by amending provisions of section 13(10) that in case of denial of exemption to a charitable

ITO (EXEMPTION), WARD, SURAT vs. GUJARAT HIRA BOURSE, SURAT

In the result, appeals filed by the Revenue (in ITA No

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

trust was the making of the profit.” We note that facts of the aforesaid case of Bharat Diamond Bourse(supra), were similar to that of the assessee and insertion of First Proviso to Section 2(15) does not alter the legal position already settled by Hon'ble Apex Court, because the said Proviso only applicable to the case where

ITO (EXEMPTION) WARD, SURAT vs. GUJARAT HIRA BOURSE, SURAT

In the result, appeals filed by the Revenue (in ITA No

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

trust was the making of the profit.” We note that facts of the aforesaid case of Bharat Diamond Bourse(supra), were similar to that of the assessee and insertion of First Proviso to Section 2(15) does not alter the legal position already settled by Hon'ble Apex Court, because the said Proviso only applicable to the case where

SHREE BRAHMAJYOTI SANSKAR DHAM TRUST ,SURAT vs. THE COMMISSIONER OF INCOME TAX, (EXEMPTION) AHMEDABAD , AHMEDABAD

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

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.74/Srt/2025 Assessment Year: (2025-26) (Hybrid Hearing) Shree Brahmajyoti Sanskar Dham Trust, Vs. Cit (Exemption), 9, Gopal Krushna Society, Behind Arihant Ahmedabad Park, Ambika Niketan, Athwalines, Surat – 395007, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aawts9225R (Appellant) (Respondent) Appellant By Shri Hiren Vepari, Ca Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 19/08/2025 Date Of Pronouncement 31/10/2025

10 of the trust, which is at page 8 of the order and held that the objects of the trust are religious in nature and not charitable in nature as per section

SHREE SUIGAM KHODADHOR PANJARA POLE,SURAT vs. ITO, EXEMPTION WARD, SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

10. In the case of Sarvodaya Charitable Trust vs. Income Tax Officer. (Exemption) [2021] 125 taxmann.com 75 (Gujarat)/[2021] 278 Taxman 148 (Gujarat)[09-12-2020], the High Court held that where assessee, a public charitable trust registered under section

OM TAPOVAN CHARITABLE TRUST,ANKLESHWAR vs. CIT(EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

trust under section 80G(5) of the Act vide application dated 10-08-2022 before the ld. CIT(Exemption). The learned CIT(Exemption) found that the application of the assessee contains nature of activity as “Religious cum Charitable

PATIDAR SAMAJ,SURAT vs. CIT(EXEMPTION), AHMEDABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl.

10, or section 11 or section 12, for any previous year ending on or before the date of such application, at any time after the commencement of such activities,] and such trust or institution is registered under section 12AB;]” Procedure for fresh registration. 12AB. (1) The Principal Commissioner or Commissioner, on receipt of an application made under clause

SHREE RAM KABIR MANDIR TRUST,SURAT vs. CIT(EXEMPTION), AHMEDABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethsl.

10, or section 11 or section 12, for any previous year ending on or before the date of such application, at any time after the commencement of such activities,] and such trust or institution is registered under section 12AB;]” Procedure for fresh registration. 12AB. (1) The Principal Commissioner or Commissioner, on receipt of an application made under clause