2010 (3) TMI 1245

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....ee while impugning the orders of the Revenue Authorities Below contended that the assessee is a trust which is registered under sec. 12A of the Income-tax Act, 1961. It is running educational institution, namely, Harshan Dass Dental College at Dasana, Ghaziabad. According to the AO, the department had received information that assessee had received accommodation entry amounting to Rs. 40,05,000. Therefore, the A.O. had issued notice under sec. 148 and reopened the assessment. In the assessment proceedings, AO has confronted the assessee that it had received donation of Rs. 95,94,500 during the year and assessee was asked to explain the details of donors along with their PANs and the details of cheque numbers etc. The assessee had submitted ....

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....2 was not given to the assessee on this amount and it has been, therefore, taxed. The possibility of introduction of assess's own unexplained money cannot be ruled out. 3. We have duly considered the rival contentions and gone through the record carefully. The assessee is a trust. It is registered under sec. 12A of the Income-tax Act, 1961 and it is running on an education institution. There is no dispute with regard to these facts. It has received a donation of rupees more than 95 lacs. It has produced the complete details of the donors, PAN number and the date of donations etc. The A.O. has not disputed with regard to the details submitted by the assessee except in one case i.e. donation received from Shri Surender Pal Singh. It is als....