2025 (2) TMI 1077

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....er of the CPC, Bengaluru, (in short, 'the A.O.') passed under section 143(1)of the Act, date of order21/02/2018. 2. The assessee has taken the following grounds of appeal:- "GROUND NO. 1: FAILURE OF CIT(A) TO ALLOW EXEMPTION U/S. 11 OF ADDL/JCIT(A)-5 CHENNAI DT, 22.10.2024. GROUND NO.1 : FAILURE OF CIT(A) TO ALLOW EXEMPTON U/S 11 OF Rs. 86,80,000 The Id. CIT(A) erred in laws and facts in dismissing the ground for grant of exemption u/s 11 of Rs. 86,80,000 without adjudicating the same on merits by allowing the claim for exemption u/s 11 on appreciation that the required Audit report in form 10-B was on record and the appellant has also applied for condonation if any of delay in filling the said report. Your appellant pleads that the e....

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....JUDICATING GROUND NO. 2 ΤΟ 4 The Id. CIT (A) erred in laws and facts in passing the order u/s. 250 dt. 22.10.2024 and dismissing the appeal without adjudicating ground no. 2 to 4 contested before him in an appeal filled u/s. 246A before him which ground were duly raised, contested and the fact relating to which were recorded in the statement of facts. Your appellant prays that the said Ground of Appeal, 2 to 4, to be adjudicated and allowed after hearing your appellant. GROUND NO. 5. ASSESSMENT OF TOTAL INCOME The Id. CIT(A) erred in laws and facts in ignoring the action of AO - CPC of assessing the total income at Rs. 88,10,900 against the returned income of Rs. 1,30,900 and in process making an addition/disallowance of R....

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.... charitable purpose. During the impugned assessment year, the assessee claimed exemption under sections 11 and 12 of the Act and section 12A is constituted validly. But during the impugned assessment year, the assessee filed the return under section 139(4A) but delay in Form 10B which is obtained on 30/09/2016 under sub sections (2)of the section 33 and 34 of Bombay Public Trust, 1950. On the basis of this audit report the expenses are duly claimed by the assessee trust. During processing of return under section 143(1), the Ld.AO disallowed the exemption under section 11 and the tax was determined amount to Rs. 88,10,900/-. The assessee filed a rectification petition under section 154, but without giving an opportunity to assessee, the CPC ....