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

trust are partly religious in nature and thereby,\nrejecting grant of approval under section 80G of the Act. Section 80G(5)\nof the Act, states that this section applies to donation to any institution or\nfund only if it is established in India for a \"charitable purposes\". Further,\nExplanation 3 to Section 80G states that the term \"charitable purpose\" does

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, had substantially satisfied condition for availing benefit of exemption as a trust, it could not be denied exemption merely on bar of limitation in furnishing audit report in Form no. 10B. 7.5 In the case of CIT v. Gujarat Oil & Allied Industries [1993] 201 ITR 325 (Guj.), the High Court held that where

JAY BHAWANI MANDHANI CHARITABLE TRUST,SURAT vs. CIT(EXEMPTION), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.155/Srt/2025 (Hybrid Hearing) Jay Bhawani Mandhani Charitable Trust, Vs. Cit (Exemption), 209, 2Nd Floor, Sns Business Park, N/R Ahmedabad Subham Bungalow, U M Road, Vesu, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaetj2496B (Appellant) (Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Shri Ravinder Sindhu, Cit-Dr Date Of Hearing 16/06/2025 Date Of Pronouncement 21/07/2025

Charitable Trust expenses in the FY.2022-23. The appellant had incurred Rs.18,00,000/- towards medical relief in FY.2023-24, and Rs.81,000/- for educational expenses, Rs.12,78,000/- for medical relief and Rs.31,00,000/- for Goushala donation expenses in the FY.2024-25. It is, therefore, clear that the assessee-trust has not incurred any expenses on religious activities. Therefore, the threshold

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

section 12 of the Act by rejecting such condonation application, but an assessee, a public charitable trust past 30 years who substantially satisfies the condition for availing such exemption, should not be denied the same merely on the bar of limitation especially when the legislature has conferred wide discretionary powers to condone such delay on the authorities concerned. 34

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

section 12 of the Act by rejecting such condonation application, but an assessee, a public charitable trust past 30 years who substantially satisfies the condition for availing such exemption, should not be denied the same merely on the bar of limitation especially when the legislature has conferred wide discretionary powers to condone such delay on the authorities concerned. 34

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

section 12 of the Act by rejecting such condonation application, but an assessee, a public charitable trust past 30 years who substantially satisfies the condition for availing such exemption, should not be denied the same merely on the bar of limitation especially when the legislature has conferred wide discretionary powers to condone such delay on the authorities concerned. 34

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

section 80G(5) of the Act was rejected and he also cancelled the provisional registration granted earlier. 4. Aggrieved by the order of CIT(E), the assessee filed appeal before the Tribunal. The learned Authorized Representative (ld. AR) of the assessee filed a paper book containing 130 pages, including copy of Form 10AC granting provisional registration u/s 12AB, copy

DHARTI EKTA CHARITABLE TRUST,SURAT vs. CIT(EXEMPTION), 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.171/Srt/2025 Assessment Year: (2024-25) (Hybrid Hearing) Dharti Ekta Charitable Trust, Vs. Cit (Exemption), At & Post – Haripur, Tal – Uchchhal, Dist – Ahmedabad Tapi, Tapi – 394375, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaetd5352L (Appellant) (Respondent) Appellant By Shri Esmayeel Saherwala, Ca Respondent By Shri Ravinder Sindhu, Cit-Dr Date Of Hearing 17/07/2025 Date Of Pronouncement 21/07/2025

section 80G(5) of the Act was rejected and he also cancelled the provisional registration grated earlier. 4. Aggrieved by the order of CIT(E), the assessee filed appeal before the Tribunal. The learned Authorized Representative (ld. AR) of the assessee filed a written submission containing 93 pages, which includes order of registration u/s 12AB in From No.10AD, application

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

charitable trust registered under section 12A, had substantially satisfied condition for availing benefit of exemption as a trust, it could not be denied exemption merely on bar of limitation in furnishing audit report in Form no. 10B. 7.5 In the case of CIT v. Gujarat Oil & Allied Industries [1993] 201 ITR 325 (Guj.), the High Court held that where

SANSKRUTIK RAKSHA SAMITI,BAMROLI, SURAT vs. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1239/Srt/2024 (Physical Hearing) Sanskrutik Raksha Samiti, Vs. The Cit (Exemption), 350-351, Kashi Nagar Society, Udhna So, Ahmedabad Bamroli – 394210, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abats4036R4 (Appellant) (Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 19/02/2025 Date Of Pronouncement 29/04/2025

Trust and the donation by the assessee to it fall outside the scope of section 80G.” It is clear from the order of the Hon’ble Supreme Court that if one purpose within the institution’s overall charitable purposes is wholly, or substantially wholly, of a religious nature, then it falls outside the scope of section

INCOME TAX OFFICER (EXAMPTION) WARD, SURAT vs. SHREE SAIBABA SATSANG MANDAL, SURAT

In the result, appeal of the Revenue is dismissed

Trust from the property held for charitable or religious purposes and it also provides for application and accumulation of income. On the other hand, section 28 of the Income-tax Act deals with chargeability of income from profits and gains of business and section 29 provides that income from profits and gains of business shall be computed in accordance with

AADIVASI SAMPSABHA CHARITABLE TRUST,SURAT vs. CIT(EXEMPTION), AHMEDABAD

In the result, both the appeals filed by the assessee/applicant trust are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

Charitable Trust vs. CIT(E) Asst. Years –N.A. - 5– 9. We observe that since in the preceding paragraphs we have restored the matter regarding grant of registration under section 12A of the Act to the file of CIT (Exemptions), for de novo consideration, accordingly, it is directed that the application for grant of approval under section

AADIVASI SAMPSABHA CHARITABLE TRUST,SURAT vs. CIT(EXEMPTION) , AHMEDABAD

In the result, both the appeals filed by the assessee/applicant trust are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

Charitable Trust vs. CIT(E) Asst. Years –N.A. - 5– 9. We observe that since in the preceding paragraphs we have restored the matter regarding grant of registration under section 12A of the Act to the file of CIT (Exemptions), for de novo consideration, accordingly, it is directed that the application for grant of approval under section

GOODWILL FOUNDATION CHARITABLE TRUST,SURAT vs. COMMISSIONER OF INCOME TAX (EXEMPTION), SURAT

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

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.427 & 426/Srt/2025 (Assessment Years: 2024-25) (Hybrid Hearing) Goodwill Foundation Charitable Vs. The Cit(Exemption), Trust, Ahmedabad A 102, Sky Heaven Ved Gurukul Road Ved, Surat - 395004 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadtg9648P (Appellant) (Respondent) Appellant By Shri Harikrishna Gohil, Ar Respondent By Shri Mukesh Jain, Cit-Dr Date Of Hearing 09/06/2025 Date Of Pronouncement 11/06/2025

section 80G of the Act was filed in Form 10AB electronically. The CIT(E) has issued only one notice of hearing, i.e., on 02.08.2024. The CIT(E) observed that applicant did not have any valid order for registration u/s 12A(1)(ac)(iii) of the Act in Form 10AD because the application

GOODWILL FOUNATION CHARITABLE TRUST,SURAT vs. COMMISSIONER OF INCOME TAX (EXEMPTION), SURAT

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

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.427 & 426/Srt/2025 (Assessment Years: 2024-25) (Hybrid Hearing) Goodwill Foundation Charitable Vs. The Cit(Exemption), Trust, Ahmedabad A 102, Sky Heaven Ved Gurukul Road Ved, Surat - 395004 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadtg9648P (Appellant) (Respondent) Appellant By Shri Harikrishna Gohil, Ar Respondent By Shri Mukesh Jain, Cit-Dr Date Of Hearing 09/06/2025 Date Of Pronouncement 11/06/2025

section 80G of the Act was filed in Form 10AB electronically. The CIT(E) has issued only one notice of hearing, i.e., on 02.08.2024. The CIT(E) observed that applicant did not have any valid order for registration u/s 12A(1)(ac)(iii) of the Act in Form 10AD because the application

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)

charitable in character for general public at large and for the purpose of granting registration under 12A of the Act, the provision of section 13(1)(b) cannot be referred to. Section 13(1)(b) is to be applied while granting exemption to the trust. In view above finding, we do not find any question of law much less

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)

charitable in character for general public at large and for the purpose of granting registration under 12A of the Act, the provision of section 13(1)(b) cannot be referred to. Section 13(1)(b) is to be applied while granting exemption to the trust. In view above finding, we do not find any question of law much less

SHREE MAHAVIDEH CHARITABLE TRUST,SURAT vs. CIT(EXEMPTION), AHMEDABAD

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

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1248/Srt/2024 (Physical Hearing) Shree Mahavideh Charitable Vs. The Cit(Exemption), Trust, Ahmedabad 0/B/4, Tribhuvan Complex, Ghod Dod Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abdts9848Q (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 80G of the Act afresh and to carry out necessary verification whether the assessee / applicant trust has expended / utilized less than 5% of its total income towards religious purposes. If that accordance with law.” 8. The facts of the present case are similar to the facts of the case cited supra. The ld. AR submitted that