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 133(6) of the Act. Banker of assessee 2 Shri Ram Education & Graminvikas Charitable Trust Vs ITO as well

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

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 6 of 15 Tribunal in the case of Mumbai Cricket Association 24 Taxmann.com, 96 wherein it has been held that the provisions of Section

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

6 Mahavir Jain Charitable Trust made. There is no reference in the seized papers that assessee-trust has given money in cash. In various questions asked during the course of statement recorded under section

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

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:

6. We have heard both the side and perused the material available on record carefully. The assesse is a trust for religious purposes & involved in the activity of running hospitals and several charitable activities. The assessee’s trust has been applying more income towards its object then its income earning for the last several years. It is also noticed that

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

6 and 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

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 passed the following order : “6. We are of the view that even though the entire income has been applied on the object of the Trust as application of income and there is no income left to be accumulated rather there is deficit even though assessee is entitled for accumulation or setting apart under section

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

6. The learned NFAC erred in considering the fact that the appellant trust has applied 85% of the voluntary contributions towards attainment of objects of trust and hence the trust is eligible for exemption of returned income amounting to Rs. 2,41,990/-. 7. The learned NFAC erred in disallowing expenditure incurred towards attainment of objects of the trust whereas

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

6. The learned NFAC erred in considering the fact that the appellant trust has applied 85% of the voluntary contributions towards attainment of objects of trust and hence the trust is eligible for exemption of returned income amounting to Rs. 2,41,990/-. 7. The learned NFAC erred in disallowing expenditure incurred towards attainment of objects of the trust whereas

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

6. The learned NFAC erred in considering the fact that the appellant trust has applied 85% of the voluntary contributions towards attainment of objects of trust and hence the trust is eligible for exemption of returned income amounting to Rs. 2,41,990/-. 7. The learned NFAC erred in disallowing expenditure incurred towards attainment of objects of the trust whereas

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

6. We have heard both the parties and perused the materials available on record. The CIT(E) has treated the assessee-trust as a religious trust in view of the clause 4(13) of the trust deed. For the appreciation of fact, the same is reproduced below: ”To build temples, maintaining them and performing all kinds of spiritual and religious

SHRI BUHARI VIBHAG DASHA SHRIMALI JAIN GNYATI SAMAJ,VALOD, TAPI, SURAT vs. THE CIT(EXEMPTION), AHEMDABAD, AHEMADABAD

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) Shri Buhari Vibhag Dasha The Commissioner Of Income Shrimali Jain Gnyati Samaj, Tax (Exemptions), Vs. Vaniya Bazar, Buhari, Tal.- Ahmedabad, Room No. 609, Valod, Dist.-Tapi, Floor-6, Aayakar Bhawan Surat-394630. (Vejalpur), Nr. Sachin Tower, Pan: Aaatu 8250 E 100 Foot Road, Anandnagar- Prahladnagar Road, Ahmedabad-380015. Appellant Respondednt

trust though both charitable and religious are not exclusively meant for a particular religious community" and, therefore section 13 (1) (b) was not attracted. Adverting to the facts of case in hand, we find that facts of this case is not at variance. 6

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 purposes. 5. However, in the case of the assessee trust, the object clause expressly contains religious purposes. Hence, the application of the assessee for approval under section 80G of the Act was rejected by the learned CIT(Exemption). 6

SHREE TAPESHWAR HANUMANJI BAJARANG CHARITY TRUST,,UMBERGAM vs. THE CIT,, VALSAD

In the result, appeal of the assessee is allowed

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No.3503/Ahd/2014/Srt िनधा"रण वष"/Assessment Year : 2014-15 Shree Tapeshwar Hanumanji Vs. Commissionert Of Income-Tax, Bajrang Charity Trust, Valsad. At & Po. Kalay, Kanglav, Via Bhilad, Umbergaon, Gujarat State. [Pan: Aakts 9068 E] अपीलाथ" Appellant ""यथ"/Respondent िनधा"रती क" ओर से /Assessee By Shri A. Gopalkrishnan, Ca राज"व क" ओर से /Revenue By Shri Sriniwas T. Bidari, Cit-Dr 13.07.2018 सुनवाई क" तारीख/ Date Of Hearing: 31.07.2018 उ"ोषणा क" तारीख/Pronouncement On आदेश /O R D E R Per O. P. Meena, Accoutant Member: 1. This Appeal Filed By The Assessee Directed Against The Order Of Learned Commissioner Of Income Tax, [Cit], Valsad, Dated 10.11.2014. 2. The Assessee Has Taken Following Ground Of Appeal : “1. On Appreciation Of The Facts & Circumstances Of The Case, The Order Passed By The Honorable Commissioner Of Income Tax Rejecting The Application For Issue Of Certificate U/S.80G Of The Act Is Contrary To Facts & Law & Prejudicial To The Appellant. 2. On Appreciation Of The Facts & Circumstances Of The Case, The Honorable Commissioner Of Income Tax Has Erred In Rejecting The Application For Issue Of Certificate U/S.80G To The Appellant Without Granting Sufficient Opportunity For Hearing & Without Issuing A Speaking Order. The Trust Had Duly Filed Application For Obtaining Registration U/S.12A & Therefore The Action Of The Honorable Commissioner Of Income

6 section 80G, registration of the trust under section 12A of the I.T.Act is essential. 9. The Hon'ble Supreme Court in the case of M/s.Queen’s Eduicational Society vs. CIT(supra) discussing therein various decision of Supreme court’s as well as High Court’s has held that the concern was charitable

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)

Trust with charitable objects, which existed for the benefit of a particular religious community qualified as charitable entity serving the public at large and this was sufficient for grant of registration under Section 12A of the Act, and the provisions of Section 13(1)(b) of the Act would be attracted only at the time of granting exemption

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)

Trust with charitable objects, which existed for the benefit of a particular religious community qualified as charitable entity serving the public at large and this was sufficient for grant of registration under Section 12A of the Act, and the provisions of Section 13(1)(b) of the Act would be attracted only at the time of granting exemption