2025 (12) TMI 56

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....are that the appellant-assessee is a Registered Society registered under the West Bengal Society Registration Act, 1961. The date of formation of the Society is on 09.12.2002. The appellant-assessee is a Trust and filed its return of income for the AY 2022-23 declaring income at 'NIL'. The case of the appellant was selected for the scrutiny under the CASS for the reason "provisional registration obtained under section 80G and large voluntary contributions received". Though the activities stated in its Memorandum of Association are for charitable purpose. Various clauses as per its MOU establishes the fact that the Society is operating as a mixed nature, i.e. of a charitable cum religious nature. Notices under section 143(2) and 142(1) of th....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ntions that any anonymous donation received by the Trust for charitable purposes does not come under the exception categories of Section 115BBC. Therefore, the AO has rightly brought the anonymous donation received of Rs. 17,65,436/- to tax. Hence, the addition made by the AO in the assessment order is sustained and accordingly the grounds raised by the appellant in this regard are dismissed". 4. Dissatisfied with the order of ld. CIT(Appeals), the assessee- Trust preferred an appeal before the Tribunal. It was the submission of the ld. Counsel for the assessee that the ld. CIT(Appeals) erred in upholding the addition of Rs. 17,65,436/- made by the ld. Assessing Officer and treated the genuine donation received as anonymous donation, on ....