TaxTMI 
TaxTMI 
2026 (1) TMI 1305
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....- "1. That, the addition of Rs. 18658039/- as unexplained money u/s 69A of the Act, on account of cash deposited in the Saving Bank account number 6176000100050071 of Punjab National Bank, Kunwar Singh Branch Ballia, in fact this account is for FEES Collection of Sri Murli Manohar Town Post Graduate College, as mentioned on the Bank statement. Thus, the source of amount deposited in the bank account is very clear and cannot be treated as unexplained 2. That, appellant is a registered educational institution, which run the four institutions, named Sri Murli Manohar Town Post Graduate College, Sri Murli Manohar Town Intermediate College, Gulab Devi Girls Post Graduate College and Gulab Devi Girls Intermediate College. This p....
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....ghts and can never be of business orientation, due to which the Govt. affiliation was given in the 1950. It was the Bank, who demanded the PAN to regulate and report the cash deposit to the Income Tax Department, otherwise these cash collections were done from the students and deposited in the Bank for the definite and well prescribed heads from the U.P. State Intermediate Education Board, institutions had no role or control to collect the fees as per their wish and desire. It is also evident that now the guardians are not interested to send their children in the Govt. aided school. 5. That, the appellant is a registered educational society and having no regular source of income or infrastructure or staff deployment and when notice....
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....ts, but no compliance was made. Consequently, the Assessing Officer proceeded to complete the assessment ex parte to the assessee and made an addition of Rs. 1,86,58,039/- by invoking the provisions of section 69A of the Act. Aggrieved against this, the assessee preferred an appeal before the Ld. CIT(A), before him also, there was no representation on behalf of the assessee. The Ld. CIT(A) has categorically noted in the impugned order that the multiple notices of hearing were issued to the assessee; however, there was no compliance. Therefore, he also passed ex parte order. Thereby, he confirmed the addition made by the Assessing Officer. Now, the assessee is in appeal before this Tribunal. 3. Apropos to the grounds of appeal, the Ld. Co....
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....iven to the assessee and despite having multiple opportunities, the assessee chose not to comply with the statutory notices and represent its case for such negligent act no reasonable cause can be attributed. He, therefore, prayed for dismissal of the appeal. 5. We have heard the Ld. Representatives of the parties and perused the material available on records. It is an admitted fact that the cash was deposited in the bank account of the assessee. The Ld. Counsel for the assessee contended that the non-compliance occurred due to reasonable cause of the institution, which is a non-profit organization (NPO), and the bank account was maintained by Sri Murli Manohar Town Post Graduate College fee collected from student was deposited, as is ev....