Tribunal Upholds CIT(A) Orders, Rejects Revenue's Appeal Grounds. No Interference, Appeals Dismissed.

The Tribunal upheld the CIT(A)'s orders for both assessment years, rejecting the Revenue's grounds of appeal. The Tribunal found no reason to interfere with the CIT(A)'s findings, which were consistent with the facts of the case and supported by previous judicial decisions. The appeals of the Revenue were dismissed.

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Issues Involved:
1. Deletion of addition on account of disallowance of capital expenditure.
2. Deletion of addition on account of disallowance of ECP contribution expenses.
3. Application of provisions of section 2(15) and rejection of benefits under sections 11 and 12 of the Income Tax Act.

Detailed Analysis:

1. Deletion of Addition on Account of Disallowance of Capital Expenditure:
The Revenue contested the deletion of an addition of Rs. 3,28,75,751/- for the assessment year 2013-14 and Rs. 1,52,43,275/- for the assessment year 2014-15, which was made on account of disallowance of capital expenditure. The AO had doubted the capital expenditure, arguing that the predominant object of the assessee-trust was to make a profit and not to spend income exclusively for charitable activities. The AO concluded that the activities carried out by the trust were in the nature of trade, business, or commercial activities, thus hitting the provisions of section 2(15) and making the trust ineligible for benefits under section 11 of the Act. However, the CIT(A) deleted these disallowances, observing that the activities of the trust fell within the ambit of preservation of the environment and were thus eligible for benefits under sections 11 and 12, considering all capital expenditures as application of income. The Tribunal upheld the CIT(A)'s decision, noting the trust's engagement in environmental preservation through a common effluent treatment plant, which is in accordance with environmental regulations.

2. Deletion of Addition on Account of Disallowance of ECP Contribution Expenses:
The Revenue also contested the deletion of an addition of Rs. 77,43,658/- for the assessment year 2013-14 and Rs. 90,45,483/- for the assessment year 2014-15, which was made on account of disallowance of ECP contribution expenses. The AO treated these expenses as capital expenditure and added them to the income of the assessee. The CIT(A) deleted these disallowances by treating the ECP contribution as part of the application of income. The Tribunal upheld the CIT(A)'s decision, noting that similar issues were raised in the assessee's case for the assessment year 2010-11, where the Tribunal allowed the claim of the assessee.

3. Application of Provisions of Section 2(15) and Rejection of Benefits Under Sections 11 and 12:
The AO applied the provisions of section 2(15), arguing that the trust's activities were in the nature of trade, business, or commercial activities, thus disqualifying it from benefits under sections 11 and 12. The CIT(A) observed that the trust's activities, which involved running a common effluent treatment plant, clearly fell within the clause of preservation of the environment, making it eligible for benefits under sections 11 and 12. The Tribunal agreed with the CIT(A), noting that the trust was engaged in preserving the environment by treating and controlling pollution, and charged fees from its members to meet operating costs. This factual position was undisputed by the AO. The Tribunal also referred to its previous order in the assessee's case for the assessment year 2010-11, where it allowed the assessee's claim, and similar judicial precedents supporting the trust's eligibility for benefits under sections 11 and 12.

Conclusion:
The Tribunal upheld the CIT(A)'s orders for both assessment years, rejecting the Revenue's grounds of appeal. The Tribunal found no reason to interfere with the CIT(A)'s findings, which were consistent with the facts of the case and supported by previous judicial decisions. The appeals of the Revenue were dismissed.

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