JAIN CITIZEN EDUCATION SOCIETY,SURENDRA NAGAR vs. ITO, WARD-2, EXMP, AHMEDABAD

ITA 737/AHD/2026Status: DisposedITAT Ahmedabad14 September 2026AY 2023-20246 pages
AI SummaryAllowed

What were the facts?

The assessee, an educational trust, claimed exemption under Section 11 and sought to accumulate 15% of its income. The tax authorities denied the benefit of accumulation, citing the belated filing of Form No. 10 and Form No. 10BB.

What did the Tribunal hold?

The Tribunal held that Form No. 10 was filed before the extended due date for filing the return of income, making the accumulation claim valid. It also ruled that the substantive claim for exemption could not be denied due to procedural delay in filing the audit report (Form 10BB) when it was available before the completion of proceedings.

What were the issues?

Whether the denial of exemption for accumulation of income is justified due to alleged belated filing of Form 10 and Form 10BB, and if substantive exemption can be denied for procedural lapses.

Which sections of the Income-tax Act were involved?

Section 10(23C),Section 11,Section 11(1)(a),Section 11(2),Section 139(1),Section 143(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

For Appellant: Shri P.B. Parmar, AR
For Respondent: Shri Amit Pratap Singh, Sr. DR
Hearing: 02.07.2026Pronounced: 14.09.2026

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:

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This appeal has been filed by the assessee against the order dated 14.01.2026 passed by the Ld. Addl/JCIT (A)-4, Chennai (hereinafter referred to as ‘Ld. CIT (A)’ in short), under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’ in short) for Assessment Year 2023-24. 2. The assessee has raised following grounds of appeal:- “Ground 1: Disallowance of accumulation of 15 per cent application of funds amounting to Rs. 43,89,286/- in terms of third proviso to section 10(23C) of the Income Tax Act, 1961 The Ld. CIT(A), NFAC, has erred in law and on facts in confirming the disallowa

The order continues below.

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