ANISHAPAM PUBLIC CHARITABLE TRUST,PATNA vs. ITO EXEMPTION WARD 1, PATNA, PATNA
What did the Tribunal hold?
The Tribunal found that the assessee did not make proper submissions regarding its exemption claims before the Assessing Officer. Therefore, the matter was remanded to the Assessing Officer to examine the applicability of Section 10(23C)(iiiad) and frame the reassessment de novo.
What were the facts?
The assessee, a charitable trust, claimed exemption under Section 11 of the Income Tax Act for AY 2022-23. Its applications for registration under Section 12A and approval under Section 80G were rejected, leading to the denial of exemption. The assessee also claimed exemption under Section 10(23C)(iiiad) as an educational institution.
What were the issues?
Whether the assessee is eligible for exemption under Section 10(23C)(iiiad) and whether proper opportunity was given to substantiate claims.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, PATNA ‘DB’ BENCH AT KOLKATA
Before: SHRI YOGESH KUMAR US & SHRI RAKESH MISHRA
PER RAKESH MISHRA, ACCOUNTANT MEMBER:
This appeal filed by the assessee is against the order of the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for AY 2022- 23 dated 27.11.2025. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal:
"
For that the grounds of appeal hereto are without prejudice to each other.
For that in the facts and circumstances of the case Id. CIT (A) is not justified in not giving proper time to substantiate its claim which is violative of princip
The order continues below.
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