GURUDAS COLLEGE,KOLKATA vs. I.T.O., WARD - 1(1), KOLKATA

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘B’ BENCH AT KOLKATA Before SHRI YOGESH KUMAR US, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER ITA No(s). 947/KOL/2026 Assessment Year(s) 2019-20 Gurudas College I.T.O., Ward-1(1), Kolkata Vs. (Appellant) (Respondent) PAN: AAALG4596K Appearances: Assessee represented by : A.B. Maitra, Advocate. Department represented by : Sanjit Kumar Das, CIT DR. Date of concluding the hearing : 17.06.2026 Date of pronouncing the order : 20.07.2026 ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the order of the Addl/JCIT(A)-Kochi [hereinafter referred to as Ld. ‘Addl/JCIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for AY 2019-20 dated 16.01.2026. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: "1. For that the learned C.I.T. (Appeals) erred in rejecting the claim of the appellant that voluntary contribution of Rs.6,44,16,999/- being grant to educational institution, college by Govt. is fully exempt u/s 10 (23C) (iiiab) of the Income tax Act, 1961 and confirming the illegal and arbitrary addition of the said amount u/s 143 (1) and rectification order u/s 154 of the I.T. Act, 1961 and dismissing the appeal without any justifying reason. 2. For that in view of the filing nil return accepted while filing the return wherein in schedule there was mention of voluntary contribution of Rs. 6,44,16,999/- being grant by the Govt. which is exempt u/s 10 (23C) (iiiab)

Voluntary Govt. Contribution exempt Assessment under u/s 10 (23C) (iiiab) of the I.T. Reason Year Act, 1961 2019-20 6,44,16,999/- added back u/s 143 (1) confirmed u/s 154 rectified u/s 154 and addition was deleted 2020-21 11,51,10,495/- added back u/s 43 (1) with the late fee of 1000/- Return filed treated as invalid. Notice u/s 2021-22 - 148 pending No addition and assessed 2022-23 129706599/- u/s 143(1) with no payment due No addition and assessed 2023-24 1,27,154,444/- u/s 143(1) with no payment due

Incom Govt. Assess Retu Assess Exemp e Exemp Assess Remark Grant ed as rned ed ted eligibl t ment s / Receiv Incom Inco Incom Incom e for Incom year Status ed e me e e exempt e ion Rs.6,44, 16,999 being Govt. Grant received for salary of Teachin 2019- 64,416 6,44,1 64416 64,416 g and Nil Nil 0 20 ,999 6,999 999 ,999 Non- Teachin g Staff consider ed as Income Assesse d U/s. 143(1) /154 Assesse d u/s. 143(1) 2020- 115,11 115,11 115,11 11,110 with Nil Nil Nil 21 0,495 0,495 0,495 ,495 demand of Rs.5,191 ,340 After Rectific ation request 2020- 115,11 115,11 115,11 115,11 11511 the Nil Nil 21 0,495 0,495 0,495 0,495 0495 assessm ent was rectified U/s. 143(1)/1

Incom Govt. Assess Retu Assess Exemp e Exemp Assess Remark Grant ed as rned ed ted eligibl t ment s / Receiv Incom Inco Incom Incom e for Incom year Status ed e me e e exempt e ion 54 with demand of Rs.1,000 as Late Fee Return filed treated as invalid . Return filing under 2021- Notice 22 U/s. 148 of the Income Tax Act, 1961 is pendin g. Assesed U/s. 2022- 129,70 129,70 129,70 143(1) 350 347 347 Nil 23 6,597 6,597 6,597 with no payment due Assesed U/s. 2023- 127,15 163,96 163,96 143(1) 600 600 600 Nil 24 4,444 6,317 6,317 with no payment due