Appeal partially allowed: donation as income confirmed, expenses disallowed for exceeding jurisdiction.

The Tribunal partially allowed the appeal by confirming the addition of the donation amount as income due to lack of registration under section 12A. However, the disallowance of expenses under Advertisement, Rent, and other heads was deleted as the Assessing Officer exceeded jurisdiction by considering issues not referred to in the order under section 263.

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Issues:
1. Addition of donation amount in the income of the assessee.
2. Disallowance of expenses under different heads.

Analysis:
Issue 1: Addition of donation amount
The appellant contested the addition of &8377; 2,00,34,095 received as donation by the Assessing Officer. The Assessing Officer treated the donation as unexplained cash credit under section 68 of the Income-tax Act due to the lack of registration under section 12A, making the appellant ineligible for benefits under section 11. The ld. CIT(A) upheld the addition, stating that without registration under section 12A, the donations were to be treated as income. The Tribunal confirmed this decision, emphasizing the need for relevant information to verify the donations' identity, creditworthiness, and genuineness.

Issue 2: Disallowance of expenses
Regarding the disallowance of expenses under Advertisement, Rent, and other heads, the appellant argued that the Assessing Officer exceeded jurisdiction by considering these issues not referred to in the order under section 263 of the Act. The Tribunal agreed with the appellant, citing precedents that limit the Assessing Officer's scope to issues specified in the order under section 263. Consequently, the Tribunal set aside the ld. CIT(A)'s decision and deleted the additions made on account of Advertisement, Rent, and other expenses.

In conclusion, the Tribunal partially allowed the appeal, confirming the addition of donation amount but deleting the disallowance of expenses not within the scope of the order under section 263.

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