ENTREPRENEUR WOMAN ORGANIZATION SOCIETY,JAIPUR vs. ITO WD 6(2),JPR, JAIPUR

IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “SMC” BENCH, JAIPUR BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER& SHRI T. R. SENTHIL KUMAR, JUDICIAL MEMBER , ITA No.27JPR/2026 (Assessment Year:2023-24)

Entrepreneur Woman Vs. The ITO, Organization Society Ward-6(2), C/o CA R.S. Poonia, D- Jaipur. 82-B Siwad Area, Krishna Marg, Babu Marg, Jaipur. �थायीलेखासं./जीआइआरसं./PAN/GIR No: AABAE7313A Appellant .. Respondent Appellant by : Sh. Ms. Payal Jhorar, Advocate Respondent by : Mrs. Aarti Rawat, JCIT

Date of Hearing 08.07.2026 Date of Pronouncement 21.07.2026 O R D E R

Per: Smt. Annapurna Gupta, Accountant Member The present appeal has been filed by the assessee against the order passed by the Office of the National Faceless Appeal Centre, Delhi (hereinafter referred to as “Ld. CIT(A)”), dated 26.12.2025 under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. The grounds of appeal raised by the assessee are read as under:-

P a g e | 2 ITA No.27/JPR/2026 Entrepreneur Woman Organization Society “1. That on the facts and in the circumstances of the case the Ld. Commissioner of Income Tax (Appeals) is wrong, unjust and has erred in law by confirming the disallowance of revenue expenditure amounting of Rs. 71,500/- which is wrong and bad in Law. Kindly allow the expenditure. 2. That on the facts and in the circumstances of the case the Ld. Commissioner of Income Tax (Appeals) is wrong, unjust and has erred in law in confirming the addition of Rs. 40,000/- on account of Unexplained money u/s 69A of the Income Tax Act, 1961 which is wrong and bad in Law. Kindly delete the addition. 3. That the appellant craves permission to add to or amend to any of the above grounds of appeal or to withdraw any of them.”

P a g e | 3 ITA No.27/JPR/2026 Entrepreneur Woman Organization Society exemption or deduction had been claimed under Section 12A of the Act nor any donations taken under Section 80G of the Act. The assessee had filed its return of income declaring net profit of Rs.9,230/- earned , without claiming any deduction or exemption. The AO has acknowledged the fact of the assessee having returned its profit to tax and having not claimed any exemption of its income by computing the assessee’s income, taking income returned as per return filed under Section 139(1) of the Act of Rs.9,230/- which was the profit earned by the assessee during the year from its activities and reflected in its Income &Expenditure account, copy of the said account duly audited reflecting the surplus of Rs.9,230/- earned ,was filed before us at page one of paper bookalong with copy of return income and computation of income. It is evident therefore, that assessee’s case was taken up for compulsory scrutiny, though the assesses case did not fit into the norms specified for the said purpose as per department’s guidelines itself . Having noted so, We further find that the entire claim of expenses incurred by the assessee in its activities of Ewo (Entrepreneur Woman Organization) Skill Development programme, on account of the following 1. Ewo Skill Development Programme Rs. 19,000/- 2. Ewo Magazine expenses of Rs. 34,5000/- 3.Salary to trainer of Rs. 18,000/-, were disallowed for want of substantiation of the same with cogent evidences. 5. We have noted that the AO, however, has accepted the receipts shown by the assessee towards its projects of Ewo Skill Development of Rs.15,000/- , Ewo Magazine of Rs. 60,000/-. We find it completely absurd on the part of

P a g e | 4 ITA No.27/JPR/2026 Entrepreneur Woman Organization Society the Assessing Officer to have denied the claim of expenditure on account of skill development projects having accepted the assessee to have carried out the said projects .Moreover considering the meager level operation of the assessee society, having earned barely Rs.80,733/- during the year from the projects undertaken , membership fees etc. as reflected in its audited financial statements, the assessee is too small an entity to have been subjected to the rigors of assessment and coupled with the fact that as per the departments own guidelines the case could not have been taken up for compulsory scrutiny, the entire exercise of framing assessment in the present case, we find, is meaningless and futile. Moreover the denial of entire claim of expenditure incurred on projects carried out by the assessee is unfair and unjust when the Revenue has not disputed the fact of the projects being carried out by the assessee. We see no reason to uphold the disallowance of expenses to the tune of Rs.71,500/-. 6. Further we have noted that addition on account of unexplained donation to the tune of Rs. 40,000/- has also been made in the hands of the assessee. The AO noted from the insight portal that the assessee had received donation of Rs.40,000/- from one Puneeta Chauhan. The assessee however, denied having received any donation and even the audited financial statements of the assessee filed before us do not reveal any donation to have been received by the assessee. The AO has made addition merely because the assessee failed to explain anything about the said donation. 7. In our view, the assessee having denied to have received any donation and its financial statements corroborating the said fact, the onus was on the Revenue to prove that the assessee did receive any donation. The Revenue

P a g e | 5 ITA No.27/JPR/2026 Entrepreneur Woman Organization Society could not have shifted the onus on the assessee, more particularly to prove the negative which is impossible .And the Revenue having no basis other than the reflection of some data in this regard in the insight portal, we hold that there was no basis at all for making any addition on account of donation of Rs.40,000/- allegedly received by the assessee. 8. In light of the above, we delete the addition made to the income to the assessee, both on account of disallowance of expenditure of Rs. 71,500/- and unexplained donation of Rs. 40,000/-. 9. In effect, the appeal of the assessee is allowed in above terms. Order pronounced in the open court on 21.07.2026. Sd/- Sd/- (T.R. SENTHIL KUMAR ) (ANNAPURNA GUPTA) JUDICIAL MEMBER ACCOUNTANT MEMBER

Jaipur Dated 21.07.2026 *Santosh Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order,

Asst. Registrar ITAT, Jaipur