SHREE RAJGOR BRAHMIN PRAGATI MANDAL CHARITABLE TRUST,MUMBAI vs. ITO (E) WARD2(3) MUMBAI, MUMBAI

ITA 3433/MUM/2026Status: DisposedITAT Mumbai09 September 2026AY 2023-247 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(A) had not properly adjudicated the assessee's contentions, including the applicability of tax rates and the admissibility of expenses, and had merely endorsed the AO's order without independent application of mind. Therefore, the case was remitted back to the AO.

What were the facts?

The assessee, a charitable trust, appealed against the CIT(A)'s order confirming the addition of Rs. 2,05,000/- by treating member donations as taxable income. The assessee argued that donor details were provided and the principle of mutuality applied, while the AO and CIT(A) found a lack of verifiable donor information.

What were the issues?

Whether member donations to a charitable trust are taxable as income when donor details are allegedly not adequately provided, and whether the CIT(A) properly adjudicated all grounds of appeal including taxability and expenses.

Which sections of the Income-tax Act were involved?

Section 115BBC,Section 164(2),Section 270A

AI-generated summary — verify with the full judgment below

Before: SHRI CHALLA NAGENDRA PRASAD & SHRI PRABHASH SHANKAR

For Appellant: Shri Dinesh Rasiklal Shah, AR
For Respondent: Shri Swapnil Savant, (Sr.DR)
Hearing: 07.07.2026Pronounced: 09.09.2026

PER PRABHASH SHANKAR [A.M.] :- The instant appeal emanating from the appellate order dated 16.02.2026 is preferred by the assessee Trust against the order passed by the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)”]

P a g e | 2 A.Y. 2023-24 Shree Rajgor Brahmin Pragati Mandal Charitable Trust pertaining to assessment order passed u/s. 143(3) r.w.s. 144B of the Income-tax Act, 1

The order continues below.

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