IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/TAX APPEAL NO. 291 of 2012 ==========================================================

CHIEF COMMISSIONER OF INCOME TAX (OSD) - RAJKOT Versus SUKHSAGAR EDUCATION & CHARITABLE TRUST ==========================================================

Appearance:

MAUNIL G YAJNIK(9346) for the Appellant(s) No. 1 MR B S SOPARKAR(6851) for the Opponent(s) No. 1 ==========================================================

CORAM:HONOURABLE MR. JUSTICE A.S. SUPEHIA and HONOURABLE MR. JUSTICE PRANAV TRIVEDI Date : 03/12/2025

ORAL ORDER

(PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA)

1. At the outset learned advocates appearing for the respective parties have fairly submitted that the substantial question of law framed in the present tax appeal would get answered in view of the judgment passed by the Hon’ble Supreme Court in case of Ananda Social and Educational Trust Vs. Commissioner of Income Tax and Anr. Reported in (2020) 17 SCC 254 as well as the case of Commissioner of Income Tax (Exemptions) Vs. International Health Care Education and Research Institute reported in (2025) SCC Online SC 607.

2. In the present Tax Appeal, the appellant department has assailed the Jud