SHIKSHAN PRASARAK MANDAL,CHANDRAPUR vs. ITO WARD-2, CHANDRAPUR

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ITA 414/NAG/2025Status: DisposedITAT Nagpur11 June 2026AY 2015-163 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the evidence submitted by the assessee regarding donations requires verification. Therefore, the impugned order was set aside to the AO for fresh adjudication, including calling for additional evidence.

What were the facts?

The assessee received donations and the Assessing Officer (AO) made additions under Section 69A for failure to provide the identity of donors. The CIT(A) dismissed the appeal, holding that the assessee failed to establish the nature and source of cash deposits.

What were the issues?

Whether the assessee provided sufficient evidence to establish the identity and source of donations, and if the CIT(A) properly appreciated the submissions made by the assessee.

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 144,Section 144B,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, NAGPUR BENCH :: NAGPUR

For Appellant: Shri Rachit Thakar, Advocate
For Respondent: Shri Surjit Kumar Saha, Sr.DR
Hearing: 10.06.2026Pronounced: 11.06.2026

PER BENCH:

This appeal filed by the assessee is directed against the order of National Faceless Appeal Centre, Delhi, (for short, “CIT(A)”), dated 03/06/2025 passed under section 250 of the Income Tax Act, 1961 (for short, “Act”) which is emanating from the assessment order dated 22.03.2024

ITA No. 414/NAG/2025 (Shikshan Prasarak Mandal) passed u/s. 147 r.w.s. 144 r.w.s. 144B of the Act, for the Assessment Year (AY) 2015-16.

2.

On hearing both the sides, we find that apart from grounds on merits, assessee also raised a ground that its submissions were not appreciated by the NFAC. Ld.DR has, though, relied on the impugned order, we find that the issue involved is the additions made u/s. 69A on account of alleged failure of the assessee to provide identity of the persons from whom donations received during the year. Now before us, on behalf of the assessee, it is contended that assessee has all the relevant evidences including the details of PAN cards etc. of the persons who had given donations, the same have been filed in the form of paper book. NFAC had dismissed the appeal of the assessee holding that assessee failed to establish the nature and source of cash deposits, we are of the considered view that evidences on which assessee relying require verification. Thus, to give the assessee an opportunity to contest the matter on merits, the impugned

ITA No. 414/NAG/2025 (Shikshan Prasarak Mandal) order is set aside to the files of Ld. AO for fresh adjudication including calling for additional evidences and after verification of the same, pass an order afresh. Corresponding ground of appeal raised by the assessee is allowed for statistical purposes.

3.

In the result, appeal filed by the assessee is allowed for statistical purposes.

Order pronounced in open Court on 11.06.2026 sd/- sd/- ANUBHAV SHARMA KHETTRA MOHAN ROY ACCOUNTANT MEMBER JUDICIAL MEMBER

Nagpur: Dated: 11/06/2026 vr/- Copy to: 1. The Assessee 2. The Revenue 3. The Pr.CIT concerned. 4. The DR, ITAT, Nagpur 5. Guard file. By order Vukkem Digitally signed by Vukkem Rambabu Rambabu Date: 2026.06.11 15:16:11 +05'30' Senior Private Secretary ITAT, Nagpur

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