SHREE MANAV SHEVA SAMITI,BIJAI NAGAR vs. ITO WD-2(2), AJMER, AJMER

ITA 213/JPR/2026Status: DisposedITAT Jaipur18 September 2026AY 2023-248 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that denial of exemption under Section 11 solely due to discrepancies in the return and audit report, especially when a revised audit report clarified them, is not sustainable. The assessee had substantially applied its income for charitable activities and was eligible for exemption.

What were the facts?

The assessee, a registered charitable trust, received gross receipts of Rs. 15,84,820/- and claimed to have applied 86.72% for charitable purposes. However, discrepancies arose between the Income Tax Return and the audit report (Form 10BB) regarding the application of funds and corpus balance.

What were the issues?

Whether the denial of exemption under Section 11 for a registered charitable trust is justified due to technical discrepancies between the ITR and Form 10BB, and whether the CPC can make adjustments beyond prima facie adjustments under Section 143(1).

Which sections of the Income-tax Act were involved?

Section 11,Section 12A,Section 143(1)

AI-generated summary — verify with the full judgment below

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

Before: SHRI KULDIP SINGH & SHRI PRAKASH, ACCOUNTANCT MEMBER

PER : KULDIP SINGH, JUDICIAL MEMBER:-

The Appellant, Shree Manav Seva Samiti by filing the present appeal, sought to set aside the impugned order dated 17.12.2025 passed by the Additional/Joint Commissioner of Income Tax (Appeals)- 2, Lucknow [hereinafter referred to as the ‘JCIT(A)’] qua assessment year 2023-24 on the grounds inter-alia that:- “1. The impugned order dated 17.12.2025 passed by the Id. Addl./JCIT(A)-2, Lucknow u/s 250 of the Act is bad in law and on facts of the case, for want of juri iction and various other reasons and hence, the same kindly be quashed.

I.T.A No. 213/JPR/2026 Page No 2 Shree Manav Seva Samiti

2.

The Id. Addl./JCIT(A

The order continues below.

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