2024 (9) TMI 1332

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....there was no representation on behalf of the assessee despite repeated notices issued to the assessee through RPAD as well as through e-mail on the e-mail ID given by the assessee in Form-36. The notices issued through registered post AD has been received back with the postal remarks that on repeated visits the door is found locked. Accordingly, the Bench proposed to hear and dispose off this appeal ex-parte. 3. The assessee has raised following grounds of appeal: "1. Under the facts and in law, the learned CIT(A) erred in confirming disallowance of the exemption u/s 10(23C)(ad) and/or 10(23C)(vi) 1.1 Under the facts and in law, the learned CIT(A) erred in disallowing the expenditure Incurred for running the education institute / schoo....

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....to be rectified as exemption u/s 10(23C)(iiiad) of the Act. The CPC while processing the return u/s 143(1) of the Act disallowed the claim of exemption u/s 10(23C)(iiiad) of the Act on the ground that the gross receipt of the assessee exceeds Rs.1 crore and consequently the entire gross receipts was assessed to tax. The assessee challenged the order of CPC before CIT(A) but could not succeed. The Ld. CIT(A) has upheld the assessment made by the CPC by disallowing the claim of exemption u/s 10(23C)(iiiad) of the Act on the ground that the gross receipt of the assessee exceeds Rs.1 crore as prescribed monetary limit u/s 10(23C)(iiiad) of the Act. 5. It is pertinent to note that the assessee has specifically raised the point before CIT(A) tha....