EKADANTHA CHARITABLE TRUST ,BENGALURU vs. AC/DCIT, CPC, , BENGALURU

ITA 2756/BANG/2025Status: DisposedITAT Bangalore24 September 2026AY 2023-248 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that while the assessee may not be eligible for exemption under Section 11 due to non-compliance, the entire gross receipts cannot be taxed. Revenue expenditures incurred to earn such income, along with depreciation, must be allowed as deductions.

What were the facts?

The assessee, a charitable trust, filed a return declaring Nil income. The CPC processed the return under Section 143(1) and treated the entire gross receipts as taxable income, denying deductions for application of funds and accumulation. This was primarily due to the late filing of Form 10B and lack of registration data.

What were the issues?

Whether the entire gross receipts of a charitable trust can be taxed when exemption under Section 11 is denied, or if revenue expenses should be allowed. The procedural lapse of late filing of Form 10B and its impact on claiming deductions.

Which sections of the Income-tax Act were involved?

Section 11,Section 12A,Section 143(1),Section 119(2)(b)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A’’BENCH: BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: CA N. Rama Raju, A.R
Hearing: 15.07.2026Pronounced: 24.09.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the ld. Addl./JCIT(A), Thane, dated 03.09.2025 vide DIN & Order No. ITBA/APL/S/250/2025-26/1080309140(1) passed u/s 250 of the Income Tax Act, 1961 (in short “the Act”) for the assessment year 2023-24. 2. The assessee has raised the following grounds of appeal: -

1.

The order of the learned CIT(A) concluded under the provisions of section 250 of the Act in as is against the Appellant, is opposed to law, M/s. Ekadantha Charitable Trust, Bengaluru weight of evidence,

The order continues below.

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