2026 (8) TMI 953

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.... under section 154 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') by the CPC (hereinafter referred to as the 'AO') pertaining to Assessment Year (A.Y.) 2021-22. 2. The assessee has raised the following grounds of appeal: "BEFORE THE INCOМЕ ТАХ АPPEALTE TRIBUNAL, NEW DELHI IN THE MATTER OF MATRI MANDIR SAMITI AY 2021-22 ASSESSMENT U/S 143(1) GROUNDS OF APPEAL 1. The Ld. AO as well as Ld. CIT Appeal have erred in not allowing the benefit of sec 11 of the Income Tax Act by denying the utilization of Income amounting to Rs. 45,84,553.00. 2. The Ld. AO as well as Ld. CIT Appeal have erred in not appreciating that the assessee trust was registered and is registe....

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....t order is bad in law and facts of the case. 9. That the above grounds of appeal are without prejudice to one another 10. That your Appellate Prays that he be allowed to add, amend or forgo any of the above Grounds of Appeal at the time of hearing of appeal." 3. Brief facts are that the assessee is a public charitable trust which was constituted w.e.f. 30.06.1966. The assessee was registered under the old regime w.e.f. 1.4.2006 vide order of the DIT (Exemption), New Delhi dated 10.05.2007. After the introduction of new regime for registration and re-registration of the trusts, it applied for and was granted provisional registration on 31.05.2021 for A.Y. 2022- 23 to A.Y. 2024-25. Meanwhile, the assessee had filed his re....