IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER Assessment years : 2015-16, 2016-17, 2019-20 & 2022-23 RUKMINI EDUCATIONAL Vs. The Principal Commissioner CHARITABLE TRUST, of Income Tax (Central), No.11, Divyashree Chambers, ’A’ Wing, Bengaluru.

O’Shaughnessy Road, Shanthinagar, Bengaluru – 560 025. PAN: AABTR 1107Q APPELLANT RESPONDENT Appellant by : Shri Vijaya Mehta, CA & Shri Avinash Mallya, Advocate Respondent by : Smt. Srinandini Das CIT(DR)(ITAT), Bengaluru.

Shri Shivanand H Kalakeri, CIT(DR)(ITAT), Bengaluru. Date of hearing : 06.08.2025 Date of Pronouncement : 04.11.2025

O R D E R

Per Prashant Maharishi, Vice President

01. These are 4 appeals filed by M/S. Rukmini Educational Charitable Trust (the assessee/appellant) for the assessment years 2015-16, 2016-17, 2019-20 & 2022-23 against the order passed u/s. 12AB(4)(ii) of the Income-tax Act, 1961 [the Act] by The Principal Commissioner of Income Tax (Central), Bengaluru [ld. PCIT] on

30.9.2024 cancelling the registration granted to the assessee u/s 12 AA of the Income-Tax Act.

02. At the request of the assessee, we take the lead appeal for AY 2015-16 in ITA No. 2106/Bang/2024.

03. The brief facts of the case show that assessee, charitable Trust was established in 2003 and registration was granted u/s. 12AA of the Act on 19.3.2003 and subsequently u/s. 12AB on 24.9.2021. The original name of the trust was Bheemaneni Educational System Trust. The main objects of the trust of educational activities are as under:-

“(a) To promote establish and conduct activities in the fields of education, literacy, science, technology, fine arts, tourism, environmental science, adventure culture, social, medical public health and/ or any other service activities to promote all round development of the general public and of the nation.

(b) To this end establish, promote, maintain manage, takeover and / or render assistance to schools, colleges, institutions, hospitals, research establishments in the areas of medicine, engineering, science & technology, social sciences, literature, entrepreneurial units, and such other institutions for the benefit of all sections of people without any discrimination of caste, creed, race or religion.

(c) To assist, promote, establish, run, takeover and or manage orphanage, rescue and/ or half-way homes for destitute, aged and the inform and/or senior citizens without discrimination of caste, creed, race, religion, status or standing.

(d) To give out grants, scholarships, stipends, rewards, awards, certificates, financial and/ or any other help in cash or kind in furtherance of the object of the trust.”

04. The trust was managed by one, Shri P Shyamaraju as Chairman, Shri Umesh S Raju, Shri Bhaskar N Raju & Smt. Aarthi B Raju, as the trustees. A search & seizure action was carried out u/s. 132 of the Act on 23.6.2022 in the case of Divyasree Infrastructure Projects Pvt. Ltd., Shyamarju & Company (India) Pvt. Ltd., assessee and other related entities. During the search several documents were found and seized and statement u/s. 132(4) of the Act was recorded of the directors, trustees and key employees of the finance department. The search operation showed that there are evidence relating to violation with respect to the diversion of trust funds to the trustees for purchase of land in their individual capacity and advances to related entities. There was bogus expenditure debited by the trust for generation of cash through bogus billing and invoices including unaccounted and unexplained cash transactions across several years.

05. Based on the case of assessee selected for scrutiny and as per second proviso to section 143(3) reference was sent by the AO as per letter dated 5.3.2024 for cancellation of registration as under:-

07. Based on these, a show cause notice was issued to the assessee on

13.3.2024 asking to explain why the registration granted to the trust should not