TaxTMI 
TaxTMI 
2024 (7) TMI 959
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....ppeared for the revenue. 3. It was submitted by ld AR that the assessee is a charitable society which is imparting engineering studies. It was the submission that for the relevant assessment year, the assessee had filed its return of income on 23.10.2018. The return of income came to be processed u/s. 143(1) of the Act. In the course of the assessment proceedings u/s. 143(3) of the Act, on 10.5.2019, the Assessing officer had called for certain clarifications by issuance of show cause notice, wherein, issues of accumulation of income by the Trust had also been examined. It was the submission that notice u/s. 143(2) of the Act came to be issued on 22.9.2019. Further, notice u/s. 142(1) of the Act came to be issued on 25.11.2020, wherein, ....
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....Delhi ANNEXURE With respect to the assessee trust, kindly submit/attach/upload the following documents/information" 1. Brief note on activities undertaken (Main and incidental objects) 2. Address of main and branch offices (if any) 3. Copy of 12A/12AA/10(23C) registration/approval letter/certificate given by the respective registration/approval authority. 4. Copy of audited financial statements alongwith schedules to the accounts 5. Details of amounts accumulated of A.Y. 15-16, 16-17, 17-18 & 18-19. Purpose for which such amounts have been accumulated and the amounts utilized out of the said accumulations alongwith proofs/supporting documents for the utilizations. 6. De....
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....hat the Assessing Officer in the course of Face Less Assessment had not examined the issue of accumulation of Rs. 5,00,00,000/- during the relevant assessment year as also had not considered the difference of interest income of Rs. 19,15,625/-. It was the submission that both the issues had been specifically considered by the Assessing officer. It was the submission that the amount of Rs. 5,00,00,000/- was the accumulation and the same was maintained in the Schedule Bank of the assessee in Flexi/Saving account and this had been specifically queried by the Assessing officer and same was also answered and was examined with the bank account and accepted by the Assessing Officer. It was the submission that in respect of differential interest in....
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.... had not examined the issue of accumulation of Rs. 5,00,00,000/- in depth. It was the submission that the Assessing Officer had also not examined the actual difference between the interest income earned by the assessee and as accrued by the assessee as to whether the assessee was liable to be taxed in respect of differential amount of Rs. 19,15,625/-. It was the submission that the order of the ld CIT(E) is liable to be upheld. 6. We have considered the rival submissions. A perusal of the facts in the present case clearly shows that both the issues which have been raised by ld CIT(E) have been specifically queried to by the Assessing Officer in the course of original assessment proceedings. These queries have also been answered substanti....