AGARWAL PRAGATI TRUST,SURAT vs. ITO (EXEMPTION) WARD, SURAT

ITA 848/SRT/2025Status: DisposedITAT Surat17 September 2026AY 2012-136 pages
AI SummaryAllowed

What were the facts?

The assessee, a registered trust, claimed exemption for corpus donations received from 'Quadeye Securities Pvt. Ltd.'. The AO disallowed this exemption based on a director's statement. Similar disallowances were made for AY 2012-13 and 2014-15.

What did the Tribunal hold?

The Tribunal found that the factual position for the current assessment years was identical to an intermediary assessment year where the CIT(A) had already deleted the disallowance. Therefore, the Tribunal directed the deletion of the impugned disallowances.

What were the issues?

Whether the exemption claimed for corpus donations is to be disallowed based on a director's statement when the facts are identical to a previous year where the disallowance was deleted.

Which sections of the Income-tax Act were involved?

Section 11(1),Section 147,Section 143(3),Section 131,Section 133A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

For Appellant: Shri Ramesh Malpani, CA
For Respondent: Shri Ashish Kumar, Sr. DR
Hearing: 23.06.2026Pronounced: 17.09.2026

Per B.M. Biyani, AM: The captioned two (2) appeals are filed by assessee challenging two (2) separate orders, both dated 30.06.2025 and passed by learned Commissioner of Income-tax (Appeals)-Addl./JCIT(A)-4, Mumbai [“Ld. CIT(A)”], which in turn arise out of respective assessment-orders dated 19.12.2016 passed by ITO, Exemption Ward, Surat [“Ld. AO”] u/s 147 or ITA No.849/SRT/2025 Agarwal Pragati Trust 143(3) of the Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2012-13 & 2014-15. 2. The assessee is a registered trust u/s 12A by Income-tax authorities a

The order continues below.

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