2021 (10) TMI 1101

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....) has erred in passing order ex parte on 20.4.2021 i.e. when the area of the assessee and counsel of the assessee were lock down due to the spread of COVID 19. The order passed by the ld. CIT(A) is without providing proper opportunity of being heard which is against the principle of natural justice, hence, the order passed by the AO is unjustified, unwarranted and uncalled for. 2. On the facts and in the circumstances of the case, the ld. CIT(A) has erred in passing order without calling for the documents submitted with the AO in the original proceeding. Therefore, order passed without verifying the documents available with the department is unjustified, unwarranted and uncalled for. 3. On the facts and in circumstances of....

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....hrough donation would not treated as revenue receipt. The secretary of the trust produced the list of donors and amount of donation. The AO found that an amount of Rs. 44,91,791/- has been donated for the specific purpose, therefore, same were considered to be genuine and balance amount of Rs. 1,64,44,237/- was added to the total income of the assessee and determined the total income at Rs. 19,83,850/-. Aggrieved by the order of the AO, the assessee trust went in appeal before the ld. CIT(A), who passed the order ex parte confirming the addition so made by the AO. Hence, the assessee is in appeal before the Tribunal. 4. Ld. counsel for the assessee submitted that first of all the disallowances of special fund by the ld. AO while consider....

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....a Leuva Patidar Samaj Trust (2019) 103 taxmann.com 295 (Surat) iv) Visakhapatnam Tribunal in ITO (Exemption) vs Hosanna Ministries (2020) 119 taxmann.com 379 (Vis) 5. Replying to above, ld. Sr DR dutifully supported the order of the ld. CIT(A) but could not point out any distinguishing feature regarding the specific purpose of donation by the donors. 6. I have heard the rival submissions and perused the record of the case. First of all, I may point out that although the assessee in its petition u/s. 154 of the Act, has agitated to consider expenditure for running of the trust but the Assessing Officer has left out the same and proceeded to consider the donations partly for specific purpose and others not for the specific purp....

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....ocial Action for 40,350/- Project social action for life transformation 15 ZMOe, Germany 5,53,004/- ACS  School/  boarding water Heater, renovation/ construction etc. 16 ZMOe, Germany 5,98,541/- Matching grant pension 17 ZMOe, Germany 8,25,000/- Education program 18 Compassion East India 3,13,654/- Projectsupportforthe month of December, 2013 19 Compassion East India 12,69,843/- Projectsupportforthe month of December, 2013 20 ZMOe Germany2,32,129/-   Afforestation program 21 ZMOe Germany 2,53,773/- Afforestation program 22 ZMOe Germany 58,208/ Widow Ashram 23 Compassion East India 6,37,707/- Project support for....