GEETAI CHARITABLE TRUST,HINGOLI vs. THE ITO EXEMPTION WARD, PUNE

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI DR. DIPAK P. RIPOTE, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA No.447/PUN/2026 िनधा�रण वष� / Assessment Year : 2016-17 Geetai Charitable Trust, Vs. ITO, Exemption Ward, 32 Geetai, Shivaji Nanded. Nagarhingoli, Hingoli S.O., Hingoli- 431513. PAN : AABTG0978L Appellant Respondent Assessee by : Shri Kishor B. Phadke : Smt. Neha Thakur (Virtual) Revenue by Date of hearing : 18.05.2026 Date of pronouncement : 25.05.2026 आदेश / ORDER PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 27.11.2025 passed by Ld. CIT(A)/NFAC for the assessment year 2016-17. 2. Facts of the case, in brief, are that the assessee is a charitable trust duly registered under Bombay Public Trust Act, 1950 and has obtained 12A registration on 20.06.2008 and engaged in providing quality education to students of backward area. The case of the

2 ITA No.447/PUN/2026 assessee was reopened u/s 147 of the IT Act by issuing notice u/s 148 on 20.03.2023 forming a reason to believe that the cash deposited in Bank of Maharashtra account of the trust amounting to Rs.77,09,410/- and assessee is non-filer for the concerned assessment year 2016-17 and thus the said amount is escaped income of the assessee. In response to the notice issued u/s 148 of the IT Act, the assessee furnished its return of income on 08.01.2024 by declaring Nil income. Subsequently, notices u/s 143(2) & 142(1) and show cause notices respectively were issued to the assessee. After considering the reply and submissions of the assessee, the Assessing Officer vide order dated 30.01.2024 completed assessment proceedings u/s 147 r.w.s. 144B of the IT Act by determining the income of Rs.4,27,92,450/- as against the Nil income returned by the assessee. The above assessed income includes addition of Rs.4,27,92,450/- u/s 68 of the IT Act being unexplained money deposited in various bank accounts. 3. Being aggrieved with the above assessment order, the assessee preferred an appeal before Ld. CIT(A)/NFAC. After considering the reply and submissions of the assessee, Ld. CIT(A)/NFAC dismissed the appeal filed by the assessee.

3 ITA No.447/PUN/2026 4. It is the above order against which the assessee is in appeal before this Tribunal. 5. We have heard Ld. Counsels from both the sides and perused the material available on record including the paper book furnished by the assessee. In this regard, it was the contention of Ld. Counsel of the assessee that the inter-bank transfers were not considered by the Assessing Officer and sum total of all the transactions was added by the Assessing Officer as income of the assessee and if one opportunity is provided to the assessee to appear before the Jurisdictional Assessing Officer, the assessee is in a position to substantiate its claim. 6. Considering the totality of the facts of the case & in the interest of justice and without going into merits of the case and with the consent of both the parties, we deem it appropriate to set-aside the order passed by Ld. CIT(A)/NFAC and restore the matter back to the file of the Jurisdictional Assessing Officer with a direction to pass assessment order afresh and as per fact and law after providing reasonable opportunity of hearing to the assessee. The assessee is also hereby directed to respond to the notices issued by the Jurisdictional Assessing Officer in this regard and to produce

4 ITA No.447/PUN/2026 relevant documents, submissions and evidences, if any, to substantiate is claim without taking any adjournment under any pretext, otherwise the Jurisdictional Assessing Officer shall be at liberty to pass appropriate orders as per law. Since we have restored the matter back to the file of the Jurisdictional Assessing Officer for passing the assessment de novo by considering the alternate plea of the assessee, the grounds raised on merits as well as legal/technical grounds are not adjudicated. 7. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced on this 25th day of May, 2026. Sd/- Sd/- (DR. DIPAK P. RIPOTE) (VINAY BHAMORE) ACCOUNTANT MEMBER JUDICIAL MEMBER पुणे / Pune; �दनांक / Dated : 25th May, 2026. Sujeet/DOC Sujeet Kumar Digitally signed by Sujeet Kumar Sharma Sharma Date: 2026.05.26 11:09:27 आदेश क� �ितिलिप अ�ेिषत / Copy of the Order forwarded to : +05'30' अपीलाथ� / The Appellant. 1. ��यथ� / The Respondent. 2. 3. The Pr. CIT concerned. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, “A” ब�च, 4. पुणे / DR, ITAT, “A” Bench, Pune. गाड� फ़ाइल / Guard File. 5. आदेशानुसार / BY ORDER, // True Copy // Assistant Registrar आयकर अपीलीय अिधकरण, पुणे / ITAT, Pune.