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

In the result, all these three appeals of the assessee are allowed for statistical purposes

Bench: Shri Pawan Singh(Physical Hearing) Navbharat Charitable Trust, I.T.O., 0, Rajpardi Jhagadia, Bharuch, Ward-1, Vs. Gujarat, Pin-393115 Bharuch. Pan No. Aactn 0979 K Appellant/ Assessee Respondent/ Revenue

Charitable Trust Vs ITO application. Additionally, it stated that the work of filing of Income-tax Return and other related forms were entrusted to a Tax consultant who did not file Form 10 due to ignorance. If condonation is not granted then it will lead to high demand resulting into shortfall of funds for achieving the objects of the trust

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)

11. Aggrieved by the order of the Ld. CIT(E), the assessee is in appeal before us. 12. The Ld. Counsel for the assessee argued that objects of trust are purely charitable without discrimination of creed, nationally or place except name, since it is started by ‘Sindhis’. The activities not doubted by Ld. CIT(E). Section

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)

11. Aggrieved by the order of the Ld. CIT(E), the assessee is in appeal before us. 12. The Ld. Counsel for the assessee argued that objects of trust are purely charitable without discrimination of creed, nationally or place except name, since it is started by ‘Sindhis’. The activities not doubted by Ld. CIT(E). Section

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

11&12. Similar view was taken by Chennai Tribunal in Veeraval Trust Vs ITO (2021) 129 taxmann.com 358 (Chennai-Trib) holding that where assessee trust charitable trust was not registered under section 12AA, voluntary donation received by it with a specific direction to be formed part of corpus of trust would fall within the ambit of Income of trust

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 does not distribute its profits among members and it does not pay higher remuneration to its employees. It is abundantly clear that the income of the mutual concern falls outside the ambit of charging section 4 of the Income Tax Act and, therefore, outside the tax net. The net effect of applicability of exemption provision in section 11

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 does not distribute its profits among members and it does not pay higher remuneration to its employees. It is abundantly clear that the income of the mutual concern falls outside the ambit of charging section 4 of the Income Tax Act and, therefore, outside the tax net. The net effect of applicability of exemption provision in section 11

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

11 on ground that audit report was not e-filed along with return. 7.4 In the case of Sarvodaya Charitable Trust v. ITO (Exemptions) [2021] 125 taxmann.com 75/278 Taxman 148 (Guj.), the High Court held that where assessee, a public charitable trust registered under section 12A, had substantially satisfied condition for availing benefit of exemption as a trust, it could

UDHNA ACADEMY EDUCATION TRUST,,SURAT vs. THE ACIT, CIRCLE-2,, SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Arjun Lal Saini(Virtual Hearing) आ.अ.सं./I.T.A No.3023/Ahd/2015 "नधा"रण वष"/Assessment Year: 2011-12 Udhna Academy Education Trust, V The Assistant Commissioner Central Road No.14, Udhyog Nagar S Of Income Tax, Circle-2, Surat. Sangh, Udhna, Surat – 394 210. . [Pan: Aaatu 0431 F] अपीलाथ" / Appellant ""यथ"/Respondent

Charitable Trust Vs. ITO in ITA No.5322 & 5323/Mum/2016 dated 28.02.2018. The Ld.AR further submits that the Learned Assessing Officer(AO) while making disallowance relied on the decision of Mumbai Tribunal in Dawat Institute of Dawoodi Bohra Community Vs JCIT in ITA No.4309/Mum/2005 dated 30.02.2014, which has been re- called by the Tribunal in M.A.No.237/Mum/2012 order dated 08.03.2013. 4

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

4. The learned NFAC erred in disallowing expenditure incurred for attaining objects of the trust without examining the fact that the accounts of the trust are duly audited and the appellant trust has incurred the expenses towards attainment of objects of the trust. 5. The learned NFAC ignored the submission made by the appellant that if the contention of appellant

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

4. The learned NFAC erred in disallowing expenditure incurred for attaining objects of the trust without examining the fact that the accounts of the trust are duly audited and the appellant trust has incurred the expenses towards attainment of objects of the trust. 5. The learned NFAC ignored the submission made by the appellant that if the contention of appellant

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

4. The learned NFAC erred in disallowing expenditure incurred for attaining objects of the trust without examining the fact that the accounts of the trust are duly audited and the appellant trust has incurred the expenses towards attainment of objects of the trust. 5. The learned NFAC ignored the submission made by the appellant that if the contention of appellant

SHRI VIDHYASAGAR SANT NIVAS TRUST,SURAT vs. CIT(EXEMPTION), AHMEDABAD

In the result, the appeal filed by the Assessee in ITA No

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

4 to 14 are not relating to particular community but for Public at Large. Thus the objects enumerated are both religious to ‘Digamber Jain Community’ and charitable activities to ‘Public at Large’. Thus mixed objects by the Trust. 8.1. Therefore the solitary question that arise for consideration is whether a Trust created before 01-04-2021 can be denied registration

SHRI VIDHYASAGAR SANT NIVAS TRUST,SURAT vs. CIT(EXEMPTION), AHMEDABAD

In the result, the appeal filed by the Assessee in ITA No

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

4 to 14 are not relating to particular community but for Public at Large. Thus the objects enumerated are both religious to ‘Digamber Jain Community’ and charitable activities to ‘Public at Large’. Thus mixed objects by the Trust. 8.1. Therefore the solitary question that arise for consideration is whether a Trust created before 01-04-2021 can be denied registration

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

11 on ground that audit report was not e-filed along with return. 7.4 In the case of Sarvodaya Charitable Trust v. ITO (Exemptions) [2021] 125 taxmann.com 75/278 Taxman 148 (Guj.), the High Court held that where assessee, a public charitable trust registered under section 12A, had substantially satisfied condition for availing benefit of exemption as a trust, it could

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

11. We find that before Ld. CIT(A) assessee has submitted detailed written submission, which we have already recorded above in the body of this 13 Mahavir Jain Charitable Trust order are not repeated for the sake of brevity. We find that Ld. CIT(A) on appreciation of submissions and the nature of incriminating material seized held that the land

GANGADHARA SAHKARI KELVANI MANDAL,SURAT vs. CIT(EXEMPTION), AHMEDABAD

In the result, in the light of the above discussion, the appeal of the\nassessee is allowed

4) Trust is also registered with NGO DARPAN. It Darpan ID is\nGJ/2023/0338260 COPY OF REGISTRATION IS ATTACHED.\n(5) Trust receive grant for salary, Nibhav Grant, washing allowance etc...from\nDO office(Grant GR is attached)\n(6) Trust do not have any religious expenditure.\n(7) To have Devi Saraswati Idol is comman matter in each and every

TRINITY EDUCATION TRUST,SURAT vs. THE INCOME TAX OFFICER, EXEMPTION WARD, SURAT

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Trinity Education Trust, The Income Tax Officer, 1C-4, Row House, Exemption Vs Muktanand Nagar, Sardar Ward, Surat. Bridge, Adajan, Surat. Pan: Aabtt4722H Appellant/ Revenue Respondent/ Assessee

section 11, the 4 Trinity Education Trust assessee can filed audit report in Form 10B even at later state either before the Assessing Officer or before appellate authority by showing a sufficient cause. Further, Hon’ble jurisdictional High Court decision in case of Sarvodaya charitable

GREEN MUMBAY LIONS EDUCATION TRUST,NA vs. ARIVS.EXEMPTION WARD, SURAT, INCOME-TAX OFFICE SURAT

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

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita No.547/Srt/2025 Assessment Year: (2023-24) (Hybrid Hearing) Green Mumbay Lions Education Vs. Ito, Trust, Exemption Ward, Opp – Ratnakar Society, C/O Sgm Surat Shiroya English School, Chhapra Road, Navsari - 396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aatg8361Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Bhupendra Shah, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 12/11/2025 Date Of Pronouncement 23/12/2025

charitable trust. It filed return of income for AY 2023-24 on 21.10.2023, declaring Nil total income after claiming exemption u/s 11 of the Act. The assessee had filed Form No.10B and 10BB as per Rule 17B of the IT Rules. The return was processed u/s 143(1) of the Act on 21.12.2024, determining total income at Rs.43

ACIT (EXEMPTION), CIRCLE-2, AHMEDABAD vs. THE SURAT DISTRICT CRICKET ASSOCIATION, SURAT

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Asst. Commissioner Of The Surat District Cricket Income-Tax (Exemptions), Association, Lalbhai Vs Circle-2, 6Th Floor, Room Contractor Stadium, Surat No.607, Aayakar Bhavan Dumas Road, Vesu, (Vejalpur), Prahlad Nagar Surat-395007 Road, Nr. Sachin Tower, Pan : Aaatt 6114 A Satellite,Ahmedabad-380 015 Appellant / Revenue Respondent / Assessee

trust and its main object is to encourage the sports and various games 3 The Surat Dist. Cricket Association specially Cricket at State as well as National level. During the year, assessee has shown gross receipt of Rs.2.30 crores and claimed application of income for its objects of Rs.3.90 crores. The Assessing Officer noted that on perusal of income