JAI TULSI TRUST,TINSUKIA vs. ITO WARD 2(4), EXEMPTION, SHILLONG

ITA 299/GTY/2026Status: DisposedITAT Guwahati27 August 2026AY 2015-167 pages
AI SummaryRemanded

What did the Tribunal hold?

The ITAT condoned the delay in filing the appeals before the CIT(A) and remitted the matters back to the CIT(A) for a fresh decision on merits. The penalty proceedings were also remitted back as they are consequential to the quantum appeal.

What were the facts?

The assessee, Jai Tulsi Trust, deposited a significant amount of cash in its bank account. The Assessing Officer treated these cash deposits as income under Section 69A of the Income Tax Act, 1961, and also initiated penalty proceedings. The assessee's appeals before the CIT(A) were dismissed due to delay.

What were the issues?

Whether the cash deposits in the bank account of an educational trust can be treated as income, and whether the penalty levied is justified. The procedural aspect of initiating reassessment proceedings under faceless jurisdiction was also raised.

Which sections of the Income-tax Act were involved?

Section 69A,Section 271(1)(c),Section 147,Section 148A,Section 148,Section 154,Section 10(23C)(vi)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, GUWAHATI

For Appellant: Shri S.P. Bhati, FCA
For Respondent: Shri Santosh Kumar Karnani, Addl.CIT
Hearing: 16.07.2026Pronounced: 27.08.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER These two appeals filed by the assessee against the separate order passed u/s 250 of the Act by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, (NFAC), Delhi (hereinafter referred to as “the CIT(A)”] DIN & order No. ITBA/NFAC/S/250/2025- 26/1086749741(1) and ITBA/NFAC/S/250/2025-26/1087464431(1) respectively. 2015-16 147 24.02.2023 1019 days 77,27,908/- 2015-16 271(1)(c) 17.03.2026 833 days 23,87,923

2.

The assessee has raised following grounds of appeal in ITA No. 299/GTY/2026:

“1. That the Learned Commissioner of Income Tax (Appea

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 69A

All 15,297 judgments and leading authorities on Section 69A →

Recent GST High Court judgments

Search GST case law →