TaxTMI 
TaxTMI 
2025 (12) TMI 1722
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....general public utility and the provisions of sections 11 and 12 shall apply in the case from the Assessment Year: 2020-21. 3. They are engaged in Charitable Activities, including preservation of environment by way of Plantation of Trees and Maintenance of trees. The Terms "Tree" / "Trees", referred in the present application, includes "Plants", "Trees", "Shrubs" and/or "Hedges". The activity of Plantation and Maintenance of Trees, inter alia, involves, Avenue Plantation, which further involves, digging of ground and making of basin, weeding, and removal of undesirable vegetation, hoeing, cleaning, levelling, watering of plants, spreading of manure/fertilizer/soil conditioners, filling/re-filling of soil, application of pesticide/insecticide/anti- termite, trimming and/or shaping including cutting for the sake of avoiding damage to hedgers/trees, taking measures to ensure survival of the Plantation, removal and replacement of dead plants, supporting plant/tree with bamboo or arranging other supports including tree guards, and generally to do anything incidental, ancillary or subservient to the principal object of Plantation of Trees and Post-Plantation Maintenance. 4. The appl....
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....ER helps towards achieving environmental stability and maintenance of the ecological balance. (c) The Forest Policy Division of Ministry of Environment & Forests, on 27/12/2012, issued the Report of the Committee, constituted to study the regulatory regime regarding felling and transit regulations for tree species, grown on private land wherein it was emphasised to expand significantly the community/ social forestry outside traditional forests requires bringing together of all stakeholders foresters, farmers, landowners, wood based industries, scientists, financial institutions and communities; necessity for encouraging the planting of trees alongside of roads, railway lines, rivers and streams and canals, and on other unutilized lands and under State/Corporate, institutional or private ownership. Green belts should be raised in urban/industrial areas as well as in arid tracts for helping in checking erosion and desertification as well as improve the micro-climate." (d) The Government of Gujarat, for the purpose of Increasing the TREE COVER, has floated Harit Van Path Yojna on PPPs basis, whereby Tree Plantation is undertaken on sides of roads. Through an MOU ente....
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.... GUJARAT) where, the activity of Planting and Maintenance of Tree (Mangroves) is held to be falling within Entry No. 1 of Notification No. 12/2017 (as amended from time to time), and is accordingly subject to NIL Rate. 7. Personal hearing was granted on 04.12.2025 wherein Shri Sumit Shingala, Chartered Accountant appeared on behalf of the applicant and reiterated the facts & grounds as stated in the application. On a query regarding the relation between Sadhbhavna Vrudh Ashram and Sadhbhavna Seva Foundation, the applicant vide letter dtd. 08.12.2025 has submitted that 'Sadhbhavna Vrudh Ashram' is not an entity in itself, but is a social recognition to the activities initiated and upbrought by the Manav Seva Charitable trust. People fondly refer the trust, as well as later constituents carrying on similar activities, as sister arm of the trust i.e. Sadhbhavna Seva Foundation (a Sec. 8 company), by 'Sadhbhavna Vrudh Ashram'. The Sadhbhavna Seva Foundation, although a sister arm of Manav Charitable Trust ('Sadhbhavna Vrudh Ashram'),is not a subsidiary of Manav Seva Charitable Trust. The Manav Seva Charitable Trust and the Sadhbhavna Seva Foundation are legally as well as functional....
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....high tree guard; necessary silviculture operations to be conducted every year along with regular watering of plants; 100% of the plants have to be planted and maintained; all the plants would be required to be kept alive and healthy; the project would be for three years; in the fourth year, 100% plants in healthy condition should be handed over by the applicant to the Forests and Environment Department ; the monitoring of the work would be done by a third party ; etc. 11. The applicant is a sister arm of Manav Charitable Trust and will be involved in similar activities as mentioned above. The applicant would also be involved in planting and maintaining trees in non-forest areas like unutilised barren lands, road sides, amidst lane dividers, on private lands and every available patch of land in its reach, where the tree can be sustainably planted and preserved. The applicant has sought a ruling as to whether the above said activity would be covered under SI. No. 1 of Notification No. 12/2017-CT(R) dtd. 28.06.2017, as amended. The said entry reads as under: - SI.No. Chapter, Section, Heading, Group or Service Code (Tariff) Description of Services Rate (per cent.) Co....
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....s, women and to create health awareness among the underprivileged children, girls and women. • To provide, assist and to create helpline/helpdesk for secondary and other complicated cases of health problems, networking with various related agencies in the local area and supporting it with whatever is necessary for providing medical aid and guidance. • To carry out activities of plantation and to create awareness about a clean environment, Planned Parenthood, and immunizations of all children against most dreaded communicable diseases and to impart knowledge about health, economical food, proper diet, clean drinking water and improvisation. • Early intervention to children with special needs in integrated manner with proper education and guidance to the public enabling them to be competent to take care of themselves. • To prevent cruelty and secure the welfare of animals throughout India. • To build, operate and manage animal Hostels and panjrapoles and to give shelter to birds and animals in sickness and old age. • To take care of the animals and Special care to rescued or stray bovine animals. To initiat....
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.... stability through preservation and restoration of the ecological balance that has been adversely disturbed by serious depletion of the forests of the country; conserving the natural heritage of the country by preserving the remaining natural forests; checking soil erosion and denudation in the catchment areas of rivers, lakes, reservoirs; checking the extension of sand-dunes; increasing substantially the forest/tree cover in the country through massive afforestation and social forestry programmes; meeting the requirements of fuel-wood, fodder, minor forest produce and small timber of the rural and tribal populations; increasing the productivity of forests to meet essential national needs; Encouraging efficient utilisation of forest produce and maximising substitution of wood, and creating a massive people's movement. As per the Policy, one of the strategy for increasing the forest cover is to encourage the planting of trees alongside of roads, railway lines, rivers and streams and canals, and on other unutilised lands under State/corporate, institutional or private ownership, which will check erosion and desertification as well as improve the microclimate (Para 4.2.2 of the Policy....