HARMONY FOUNDATION,MUMBAI vs. ITO EXEM WARD 1(3), MUMBAI

ITA 5725/MUM/2025Status: DisposedITAT Mumbai20 November 2025AY 2016-1723 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee failed to specify a definite and concrete purpose for the accumulation of income as mandated by Section 11(2). The AO's denial of the exemption was upheld.

What were the facts?

The assessee, Harmony Foundation, claimed exemption for accumulated income of Rs. 16,20,586/- under Section 11(2) of the Income Tax Act for AY 2016-17. The Assessing Officer (AO) denied this claim, stating the accumulation was for a general purpose and not a specific purpose as required by the section.

What were the issues?

Whether the accumulation of income by the assessee trust was for a specific purpose as required by Section 11(2) of the Income Tax Act, 1961, to qualify for exemption.

Which sections of the Income-tax Act were involved?

Section 11(2),Section 143(2),Section 142(1),Section 139(1)

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCH “SMC”, MUMBAI

Before: SHRI NARENDER KUMAR CHOUDHRY

For Appellant: Shri Haridas Bhat, Ld. A.R
For Respondent: Shri A.M.K. Mahadevan, Ld. Sr
Hearing: 20.11.2025Pronounced: 20.11.2025

Per : Narender Kumar Choudhry, Judicial Member: This appeal has been preferred by the Assessee against the order dated 14.08.2025, impugned herein, passed by the Ld.

Commissioner of Income Tax (Appeals) ADDL/JCIT (A) (in short Ld.

Commissioner) u/s 250 of the Income Tax Act, 1961 (in short `the Act') for the A.Y. 2016-17. 2. The Assessee during the AY under consideration has declared its total income at Rs. NIL by filing its return of income on dated 13.09.2046, which was selected through CASS under “Complete Category" for the reason accumulation of profit in Trust continuously. Therefore, the Assessee was asked to furnish certain details and documents

The order continues below.

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