SHREE VIMALJIN RELIGIOUS CHARITABLE TRUST,VAPI vs. ASSTT. DIRECTOR OF INCOME TAX, CPC, BENGALURU

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 239/Srt/2021 "नधा"रण वष"/Assessment Year: (2016-17) (Physical Court Hearing) Shree Vimaljin Religious Charitable Trust, Vs. The Acit, Cpc, 102, Shantinath Apartment, Nehru Street, Bangaluru. Vapi-396191. (Assessee) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalts6046F

4. Then after the assessee trust filed appeal before ld CIT(A) against intimation/order under section 143(1) of the Income Tax Act, dated 03.01.2018, passed by DCIT, CPC, Bangalore (hereinafter referred to as the ‘AO’) for AY.2016-17. The ld. CIT(A), has confirmed the action of the assessing officer, observing as follows: ITA 239/SRT/2021/AY.2016-17 Shree Vimaljin Religious Charitable Trust

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

section 143(3) of the Act on 11.09.2021. 4. Aggrieved by the addition in the assessment order, the assessee filed appeal before Ld. CIT(A). Before Ld. CIT(A) assessee filed detailed written 4 Mahavir Jain Charitable Trust

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 without discrimination of creed, nationally and place except name, since it is started by ‘Sindhis’ and activities of trust were not doubted by the Ld. CIT(E). The ld Counsel also argued that section 13(1)(b) of the Act, does not apply to the assessee-trust, because the school is run by assessee- trust, which is open

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 without discrimination of creed, nationally and place except name, since it is started by ‘Sindhis’ and activities of trust were not doubted by the Ld. CIT(E). The ld Counsel also argued that section 13(1)(b) of the Act, does not apply to the assessee-trust, because the school is run by assessee- trust, which is open

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

3. On the facts and in the circumstances of the case as well in law, the learned CIT (Appeals) erred in confirming the Shri Ram Education & Graminvikas Charitable Trust Vs ITO addition of Rs. 17,61,257/- for the alleged unexplained unsecured loans, in spite of the onus upon the appellant trust has fully been discharged to prove the identity

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

Charitable Trust Vs. CIT(E) Asst. Year : - - 4– the Act have overridden the provisions of sub-clause (ii) of section 80G(5) of the Act and the explanation 3

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)

3 are relating to particular Caste and Community. However the I.T.A No. 242 & 243//SRT/2025 7 Shri Vidhyasagar Sant Nivas Trust vs. CIT(E) remaining objects Nos. 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

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)

3 are relating to particular Caste and Community. However the I.T.A No. 242 & 243//SRT/2025 7 Shri Vidhyasagar Sant Nivas Trust vs. CIT(E) remaining objects Nos. 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

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

3. The brief facts of the case are that the assessee-trust filed an application for approval under clause (iii) of first proviso to sub-section (5) of section 80G of the Act in Form No.10AB electronically. The CIT(E) issued notices on 14.09.2024, 29.11.2024 and 10.12.2024. He has discussed legal background of Rule 11AA(1), 11AA(2) along with

SIGMA INSTITUTE OF TECHNOLOGY AND ENGINEERING,,VADODARA vs. THE PR.CIT, CENTRAL,, SURAT

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No. 67/Ahd/2016/Srt िनधा"रण वष"/Assessment Year : Sigma Institute Of Technology & Vs. Pr. Commissioner Of Engineering , Income-Tax (Central), At Bakrol, Near Madhav Nagar, Surat. Ajwa-Nimeta Road, Tal. Waghodia, Dist. Vadodara-390010 Pan: Aajts7182G अपीलाथ" Appellant ""यथ"/Respondent

4 of 14 cannot be considered as charitable activity as it has stepped out of the object of the trust and is engaged in profit making and unlawful activities. Section 11 of the Income-tax Act, 1961 provides for exemption of Income of the trusts involved in charitable activities. However, as per the above stated facts, it is clear that

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

Charitable Trust (4) The Appellant prays to set aside the order of Ld. CIT, EXEMPTION, AHMEDABAD declining approval u/s.80G(5) of the Act.” 3. Brief facts of the case are that the assessee filed application in Form No.10AB under sub-clause (B) of clause (iii) of first proviso to sub-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

section 12A of the Act, which was rejected by CIT (Exemptions) on the ground that the assessee/applicant trust has failed to file documentary evidences to enable him to satisfy about the genuineness of the activities of the trust, that the activities of the applicant trust are in consonance with the objects of the trust and whether the applicant trust

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

section 12A of the Act, which was rejected by CIT (Exemptions) on the ground that the assessee/applicant trust has failed to file documentary evidences to enable him to satisfy about the genuineness of the activities of the trust, that the activities of the applicant trust are in consonance with the objects of the trust and whether the applicant trust

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

3. The brief facts of the case are that the assessee filed return of income for the impugned assessment year on 30-09-2022 declaring total income at ₹1,09, 651/-. The assessee is a 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

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

4) The appellant craves leave to add, alter or vary any of the grounds of appeal.” 3. The brief facts of the case are that the assessee-trust filed an application for approval under clause (iii) of first proviso to sub-section (5) of section 80G of the Act in Form No.10AB electronically. The ld. CIT(E) issued notices

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

3. Brief facts of the case are that the assessee is a public 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

THE ITO, (EXEMPTIONS), WARD,, SURAT vs. SHREE AMBIKA NIKETAN TRUST,, SURAT

In the result, the appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhअपील सं./Ita No.667/Ahd/2017 "नधा"रण वष"/Asstt. Year:2013-2014 Income Tax Officer, Shree Ambika Niketan Trust, [Exemption] Ward, Surat, H.No.13/52, Vs. Surat. C/0 Ambika Niketan Mandir, Khan Saheb Ni Wadi, Athwalines, Surat-395001. Pan Aabts2849C (Applicant) (Responent) Revenue By : Shri Prasanjit Singh, Cit,Dr : Assessee By Kruti Kothari, C.A सुनवाई क" तार"ख/Date Of Hearing : 15/11/2018 घोषणा क" तार"ख /Date Of Pronouncement: 16/11/2018 आदेश/O R D E R Per Amarjit Singh:

4) Therefore, all the High Courts have taken identical view in favour of the assessee. This has not to be confused with the normal carry forward of business loss. The view taken is that assessee trust is entitled to get set off of excess expenditure of earlier years in subsequent assessment years as application of income. Therefore, it is respectfully

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

3. Aggrieved, by the order of AO/CPC the assessee filed an appeal before Learned CIT(A). Before the Learned CIT(A) the assessee submitted that assessee is a charitable trust and having registration under section 12A of the Act. The assessee is running school and income derived from school fees. The 2 Trinity Education Trust Assessing Officer disallowed the exemption