2025 (3) TMI 1834

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.....CIT(A) in confirming the order passed by the AO u/s. 154 of the Income Tax Act, 1961 ("the Act"); wherein the AO had levied tax at the rate of maximum marginal rate on the assessee u/s. 167B of the Act. 2. We heard the parties and perused the record. The Ld.AR submitted that the assessee is a Society registered under the Societies Registration Act, 1860 on 24-09-1969. This fact is very much known to the revenue since many years. The assessee is also granted registration u/s 12A of the Act as Society only. The Ld A.R also produced a copy of a Certificate of registration dt. 24-09-1969 issued by the Asst. Registrar of Societies, Greater Bombay region, bearing Regn. No. BOM.127/69G.B.B.S.D granted to the assessee. Referring to the provisio....

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....stered under the Societies Registration Act, 1860 (21 of 1860) or under any law corresponding to that Act in force in any part of India) in the whole or any part of the income of such association or body are indeterminate or unknown, tax shall be charged on the total income of the association or body at the maximum marginal rate : Provided that, where the total income of any member of such association or body is chargeable to tax at a rate which is higher than the maximum marginal rate, tax shall be charged on the total income of the association or body at such higher rate. (2) Where, in the case of an association of persons or body of individuals as aforesaid [not being a case falling under sub-section (1)],- (i)....