2026 (2) TMI 306

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....SH BORAD, AM This appeal at the instance of the assessee is directed against the order of Learned ADDL/JCIT (Appeals)-1, Visakhapatnam ["CIT(A)"], dated 04.09.2025 passed under section 250 of the Income Tax Act, 1961 ("Act") which is arising out of order u/s. 143(3) r.w.s. 147 of the Act, dated 20.12.2018 for the Assessment Year (AY) 2010-11. 2. The only grievance of the assessee is that the....

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..... 2011-12, the impugned disallowance could not be made by the Assessing Officer. 4. On the other hand, Ld. Departmental Representative (DR) supported the order of Ld. CIT(A). 5. I have heard rival contentions and perused the records placed before me. I observe that the assessee is a charitable trust having object of spreading education through schools and is registered with Charity Commissio....

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....in computing the income chargeable under the head 'income from other sources', as they apply in computing the income chargeable under the head 'profits and gains of business or profession'. The said amendment clearly indicates that prior to 01.04.2018, in case of assessee showing income chargeable under the head 'income from other sources', no disallowance u/s. 40(a)(ia) or 40A(2)(a) of the Act co....