2025 (6) TMI 628

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.... the assessee is directed against the orders of the National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 31.12.2024 & 23.12.2024 for Assessment Years (AY) 2015-16 & 2016-17. 2. Since identical issues are involved in these appeals, they are heard together and disposed of by this common order. For the sake of convenience and clarity the facts relevant to the appeal bearing ITA No. 243/Coc....

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....einafter called "the AO") vide order dated 24.09.2021 passed u/s. 147 r.w.s. 144B of the Act at a total income of Rs.17,92,645/-. While doing so, the AO brought to tax a sum of Rs. 21,26,524/- being the amount of donations received towards building fund by holding that in the absence of certificate of registration u/s. 12AA of the Act exemption u/s. 11 cannot be granted. 4. Being aggrieved, an ....

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....ributions received by the appellant trust towards building fund are liable to tax. Provisions of clause (2a) of sub-section (24) of section 2 defines income to include voluntary contributions received by a trust created wholly or partly for charitable or religious purposes or by an institution established wholly or partly for such purposes. Therefore, in the absence of registration u/s. 12AA of th....