PRACHEEN SHRI AGGARWAL DIGAMBER JAIN PANCHAYAT ,DELHI vs. ITO, WARD-62(1), DELHI

ITA 8142/DEL/2025Status: DisposedITAT Delhi26 May 2026AY 2018-194 pages
AI SummaryAllowed

What were the facts?

The assessee, a registered society managing temples and a bird hospital, had gross receipts of Rs 3,98,75,924. The revenue sought to tax these gross receipts, while the assessee claimed exemption for anonymous donations under Section 115BBC(2).

What did the Tribunal hold?

The Tribunal held that a significant portion of the receipts were anonymous donations exempt under Section 115BBC(2). After accounting for expenses and exempt donations, there was an excess of expenditure over income, rendering the income non-taxable.

What were the issues?

The primary issue was whether the gross receipts of the assessee society were taxable or if they qualified for exemption, particularly concerning anonymous donations.

Which sections of the Income-tax Act were involved?

Section 115BBC(2),Section 143(3),Section 12AA,Section 10(23BBA),Section 148,Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “F”: NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI M. BALAGANESH

For Appellant: Shri C. S. Agarwal, Sr. Adv, Shri RP Mall, Adv, Shri Uma Shankar, Adv
For Respondent: Shri Ravi Kant Choudhary, Sr. DR
Hearing: 23/03/2026Pronounced: 26/05/2026

PER M. BALAGANESH, A. M.:

1.

The appeal in ITA No.8142/Del/2025 for AY 2018-19, arises out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘ld. CIT(A)’, in short] dated 27.11.2025 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 06.04.2021 by the Assessing Officer, Assessment Unit, Income Tax Department (hereinafter referred to as ‘ld. AO’).

2.

Though the assessee has raised several grounds of appeal before us, the only effective issue to be decided in this appeal is as to whether the learned CIT(A) was justified in confirming the action of the learned AO in taxing the gross receipts of Rs 3,98,75,924

The order continues below.

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