SRIMATHI PAARVATHI AMMAAL EDUCATIONAL TRUST,CHENNAI vs. ACIT, EXEMPTIONS,, COIMBATORE

आदेश / O R D E R

PER MANU KUMAR GIRI, JM:

The captioned online appeal filed by the Assessee is directed against the order of the Ld. Commissioner of Income Tax (Appeals), NFAC, Delhi, [CIT(A)] dated 11.12.2025 for Assessment Year 2018- 19. 2. The appellant received the re-assessment order dated 29.03.2023 passed in terms of Section 147 r.w.s 144 r.w.s 144B of the Act from the Assessment Unit vide DIN & Order No. ITBA/AST/S/147/2022-23/1051605097(1) wherein the Assessment

ITA No 611/Chny/2026 (AY 2018-19) Srimathi P A Educational Trust Vs ACIT, E :: 2 :: Unit had disallowed the tax exemption computation benefit under Section 11 of the Act and added the sum of Rs.44,96,804/- being the amount quantified for the purpose of claiming tax exemption computation benefit in terms of Section 11 of the Act for the assessment year under consideration as against the original return of income filed on 25.10.2018, declaring taxable total income at Rs. NIL. 3. Being aggrieved with the order passed by the AO, the assessee preferred an appeal before the Ld. CIT(A) sought setting aside the disallowance of exemption by the AO. However, the Ld. CIT(A), vide its order dated 11.12.2025 dismissed the appeal of the assessee on account of non-compliance of impugned notices issued during the appellate proceedings and confirmed the order of AO. 4. Being aggrieved with the order passed by the Ld CIT(A), the assessee preferred an appeal before this Tribunal and sought an opportunity to file the relevant/necessary documents furnished by impugned notices. Further aggrieved with the order passed by the Ld.CIT(A), the assessee preferred an appeal before this Tribunal and sought an opportunity to file the relevant/necessary documents in reply to notices. He further submitted that the Ld.CIT(A) passed an ex-parte impugned order without giving proper opportunity of hearing. Hence, the appellant failed to furnish the supporting evidence in support of grounds of appeal. 5. The ld. Departmental Representative (DR), on the other hand, supported the order of the ld. CIT(A) and prayed for dismissal of the appeal. 6. We have considered the rival submissions and perused the order of the ld. CIT(A). We find that AO has passed the assessment order ex-parte u/s.144/147/144B of the Act. Hence, in the interest of

ITA No 611/Chny/2026 (AY 2018-19) Srimathi P A Educational Trust Vs ACIT, E :: 3 :: justice, we are of the view that the assessee should be granted a final opportunity to substantiate the issue under consideration. Accordingly, the impugned order is set aside and the matter is restored to the file of the AO for denovo assessment. The AO shall afford the assessee a reasonable opportunity of being heard. The assessee is directed to diligently prosecute the assessment and actively participate in the assessment proceedings. 7. In the result, appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open court on the 19th day of May 2026, in Chennai.

Sd/- Sd/- (इंतूरी रामा राव) (मनु कुमार िग�र) (INTURI RAMA RAO) (MANU KUMAR GIRI) लेखा सद*य/ACCOUNTANT MEMBER �या�यक सद*य/JUDICIAL MEMBER

चे�नई/Chennai, +दनांक/Dated: 19th May, 2026. SNDP, Sr. PS

आदेश क! ��त,ल-प अ.े-षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF