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    <title>2025 (7) TMI 1811 - ITAT DELHI</title>
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    <description>The ITAT Delhi reversed the CIT(A)&#039;s enhancement of income by disallowing the addition of gross receipts from educational activities as a new head of income, relying on precedent favoring the assessee. The tribunal deleted the depreciation disallowance, noting that the relevant statutory amendment applied only prospectively. Receipts related to development and library funds were upheld as assessable only where specific donor directions existed, which were not established here. Penalty under section 271(1)(c) was not sustained, as the tribunal found no concealment or inaccurate particulars regarding the upheld donation claims, consistent with Supreme Court rulings limiting penalty applicability. Overall, the appeal was allowed in part, with key additions and penalties deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=775743</link>
      <description>The ITAT Delhi reversed the CIT(A)&#039;s enhancement of income by disallowing the addition of gross receipts from educational activities as a new head of income, relying on precedent favoring the assessee. The tribunal deleted the depreciation disallowance, noting that the relevant statutory amendment applied only prospectively. Receipts related to development and library funds were upheld as assessable only where specific donor directions existed, which were not established here. Penalty under section 271(1)(c) was not sustained, as the tribunal found no concealment or inaccurate particulars regarding the upheld donation claims, consistent with Supreme Court rulings limiting penalty applicability. Overall, the appeal was allowed in part, with key additions and penalties deleted.</description>
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