TaxTMI 
TaxTMI 
2020 (8) TMI 939
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....n order for the sake of convenience. 2. In course of hearing, learned AR of the assessee submitted that Ground No. 1 in both years is general for which, no separate adjudication is required and Ground No. 2 in both years is regarding objection of the assessee in respect of validity of reopening and this ground is not pressed in both years. Accordingly, these grounds in both years are rejected. Thereafter, he submitted that one issue on merit in both years is regarding allowability of exemption u/s 11 and in A. Y. 2009 - 10, there is one more issue in respect of addition made by the AO of Rs. 58,69,441/- u/s 115BBC by alleging that this donation is unanimous donation. He placed reliance on the tribunal order rendered in the case of M/s Sadi....
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.... issue under similar facts was restored to CIT (A) for a fresh decision. He pointed out that in para 6 of this tribunal order, the tribunal noted that in para 6b of the order of CIT (A) in that case, it is held by CIT (A) that the assessee has not filed full details regarding the donors but in the paper book filed by the assessee before the tribunal in that case, the tribunal noted that as per these details, the assessee has given the particulars like date of receipt of donation, Receipt No., name and address of the donors and the amount of donation received and the tribunal observed that such details are sufficient to decide this aspect of the matter as to whether the donations are anonymous or not and therefore, the tribunal restored the ....
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.....2016 available on page N0.58 of the Paper look. Accordingly, we set aside the order of CIT(A) in all three years and restore the matter hack to the file of CIT(A) for a fresh decision in all the three appeals in respect of the issue regarding eligibility of the assessee for exemption under section 11 raised by the assessee as per ground Nos.4 and 5 before us in all the three years because when the impugned orders were passed. registration was not granted and it is granted later. Accordingly, ground Nos.4 and 5 of the assessee's appeal in all three yeas are allowed for statistical purposes. 5. Regarding ground No.6 in respect of anonymous donations, it was submitted by learned AR of the assessee that on pages 112 to 125 of the Paper....