RAJA RAJESWARI MEMORIAL EDUCATIONAL TRUST,NAGAPATTINAM vs. ITO, EXEMPTIONS WARD,, TRICHY

आयकरअपीलीयअिधकरण, ’ए’ �ायपीठ,चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ीयस यस िव�ने� रिव, �ाियक सद� एवं सु�ीपदमावती यस, लेखा सद�के सम� BEFORE SHRI SS VISWANETHRA RAVI, JUDICIAL MEMBER AND MS. PADMAVATHY.S, ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.No. 777/Chny/2026 िनधा�रणवष�/Assessment Year: 2018-19 Raja Rajeswari Memorial Educational Vs. The ITO (Exemption), Trust, Ward, Trichy, No. 125 Reddiar Street, 620015. Anjaruvarthalai, Mayiladuthurai, Nagapattinam, [PAN: AACTR7242M] (अपीलाथ�/Appellant) (��थ�/Respondent) अपीलाथ�कीओरसे/ Appellant by : Mr. N. Arjun Raj, Advocate ��थ�कीओरसे/ Respondent by Mr. L. Christopher Vasanth, JCIT : सुनवाईकीतारीख/Date of hearing : 02.06.2026 घोषणाकीतारीख /Date of Pronouncement 15.07.2026 : आदेश /O R D E RJ PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the order dated 14.01.2026 passed by the ld. Commissioner of Income Tax (Appeals), ADDL/JCIT (A), Bhopal for the assessment year 2018-19. 2. Ld. AR Mr. N. Arjun Raj, Advocate, drew our attention to Ground Nos. 1 to 12 and submits that the CPC, Bengaluru, denied exemption under section 11 of the Income-tax Act, 1961 (for short, "the Act") for non-

2 ITA No. 777/Chny/2026 submission of the audit report within the due date, which is evident from para No. 4.2 of the impugned order. Further, the ld. AR submits that the assessee is not interested in prosecuting the claim of exemption under section 11 of the Act and prayed to remand the matter to the file of the AO for his consideration to tax only the net income but not the gross receipts. 3. Ld. DR, Mr. L. Christopher Vasanth, JCIT, reported no objection. 4. Admittedly, the gross receipts/aggregate income with reference to section 11 is ₹38,27,426, which was added to the total income of the assessee for non-submission of the audit report within the due time. This Tribunal has consistently held that the entire gross receipts are not chargeable to tax; however, the benefit of expenditure should be given. Since the entire gross receipts were added in the hands of the assessee, considering the same and holding that the same are not chargeable to tax, we deem it proper to remand the matter to the file of the AO for his fresh consideration to tax only the net income. The assessee is at liberty to file evidence, if any, in support of his claim. The AO shall consider the same and pass the order taking into account the observations made hereinabove. Thus, the order of the ld. CIT(A) is set aside and the grounds raised by the assessee are allowed for statistical purposes.

3 ITA No. 777/Chny/2026 5 In the result, the appeal of the assessee is allowed for statistical purposes Order pronounced on 15th July, 2026 at Chennai.

Sd/- Sd/- (S. PADMAVATHY) (S.S. VISWANETHRA RAVI) Accountant Member Judicial Member

Chennai, Dated: 15.07.2026 MM आदेशकी�ितिलिपअ�ेिषत/Copy to: 1. अपीलाथ�/Appellant, 2.��थ�/ Respondent, 3. आयकरआयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय�ितिनिध/DR & 5. गाड�फाईल/GF.

MANIS Digitally signed by MANISH H MISHRA Date: MISHRA 2026.07.16 17:47:10 +05'30'