2025 (4) TMI 1730

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.... facts in rejecting the claim of deduction u/s. 35(1)(ii) of Rs. 54,25,000.00 in respect of amount of Rs. 31,00,000.00 contributed by the appellant through RTGS merely on irrelevant and untenable grounds ignoring the documents received by the appellant produced before him. On the facts and in the circumstances of the case and the legal inference, the disallowance is patently wrong. It be so held now and deduction be granted as claimed. 2. The CIT(A) erred both in law and on facts in not appreciating that the appellant submitted various documents like copies of certificates associated with Arvindo Institute of Applied Scientific Research Trust which it received on payment of contribution and appellant did all that was within its dom....

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....No. 19 in the Form No. 3CB in respect of amount admissible under Section 35(i)(ii) of the Act observed that the assessee claimed deduction under Section 35(1)(ii) of the Act of Rs. 54,25,000/- being 175% of Rs.31,00,000/- for donation given to Shri Arvindo Institute of Applied Scientific Research Trust. After issuing show cause notice, the assessee did not respond and hence the Assessing Officer made disallowance of Rs. 54,25,000/- which was claimed under Section 35(1)(ii) of the Act by the assessee. 4. Being aggrieved by the Assessment Order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee. 5. There is a delay of 282 days in filing the present appeal for which the assessee has filed the de....