2025 (2) TMI 1642

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.... Order No. ITBA/NFAC/S/250/2022-23/1051587084(1), dated 29/03/2023 for the AY 2017-18 arising out of the order passed U/s. 143(3) of the Income Tax Act, 1961 ("the Act"), dated 05/12/2019. 2. Briefly stated the facts of the case are that the assessee is a registered religious and charitable trust in Arasavalli, Srikakulam District, Andhra Pradesh. The assessee filed its return of income on 8/3/2018 for AY 2017-18 admitting a total income of Rs. NIL. Subsequently, the case was selected for scrutiny under CASS and statutory notice U/s. 143(2) was issued on 8/8/2018. In response, the assessee furnished relevant documents from time to time through e-proceedings. The assessee is registered U/s. 12A of the Act by Commissioner of Income Tax, Vi....

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.... Act and dismissed the appeal of the assessee. Aggrieved by the order of the Ld. CIT(A), the assessee is in appeal before us by raising the following grounds of appeal: "1. The order of the Ld. CIT(A) is contrary to the facts and also the law applicable to the facts of the case. 2. The Ld. CIT(A) is not justified in sustaining the addition of Rs. 1,21,96,713/- made by the Assessing Officer towards disallowance of exemption claimed U/s. 11(2) of the Act. 3. Any other grounds may be urged at the time of hearing." 4. Grounds No. 1 and 3 are general in nature and need no adjudication. 5. Ground No.2 is with respect to addition of Rs. 1,21,96,713/- by disallowing the exemption claimed U/s. 11(2) of the Act. On th....

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....It is an admitted fact that even though the assessee has filed the return of income within the completion of the respective assessment year however, the assessee has failed to file the Form-10 electronically before the due date. The assessee, as submitted by the Ld.AR, was not in knowledge about the statutory provisions requiring to file the Form-10 along with the return of income which came into effect from the AY 2016-17. The assessee has filed Form-10 manually in time as prescribed U/s. 13(9) r.w.s 139(1) of the Act before the jurisdictional Assessing Officer. The Form-10 along with Board Resolution was filed on 30/04/2017 before the jurisdictional Assessing Officer. These facts are not disputed by the Ld. Revenue Authorities. The CBDT h....