2025 (6) TMI 483

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.... (hereinafter referred to as the "Act"), dated 24.09.2024 for Assessment Year 2022-23. 2. Grounds taken by the assessee are reproduced as under: 1. On the facts, and in circumstances of the case, and in law, learned Commissioner of Income-tax (Appeal) disposed of the appeal without fixing hearing and giving opportunity of being heard. 2. On the facts, and in circumstances of the case, and in law, learned Commissioner of Income-tax (Appeal) erred in upholding action of the Centralized Processing Centre (CPC), Bengaluru in disallowing claim of exemption under section 11 of the Income Tax Act, 1961 without assigning any particular reason, and merely on the basis of providing old registration number allotted under section 12AA instead of p....

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....the old registration number. CPC processed the return whereby total income was determined at Rs. 32,27,675/-. Assessee filed an application before CPC u/s. 154 of the Act, claiming for rectification of mistake apparent from record which was processed and order was passed on 24.08.2023 against which assessee went in appeal before the Ld. CIT(A). 3.1 Assessee claims that CPC has denied exemption u/s.11 of the Act, resulting into addition of the entire gross receipts. According to the assessee, without prejudice, it was claimed that even on commercial prudence, entire gross receipts cannot be brought to tax. Corresponding expenditure incurred by the assessee to carry on its activities during the year ought to be allowed as a deduction against....