IMPERIAL COLLEGE INDIA FOUNDATION,MUMBAI vs. INCOME TAX OFFICER EXEM WARD 1(3), MUMBAI

The present appeal preferred by the Assessee is directed against the order, dated 14/05/2025, passed by the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as `the CIT(A)'] whereby the Ld. CIT(A) had dismissed the appeal against the Assessment Order, dated 10/12/2018, passed under Section 143(3) of the Income Tax Act, 1961 for the Assessment Year 2016-2017. 2. The Assessee has raised following grounds of appeal : "The Appellant prefers the following Grounds of Appeal against the order dated 14.05.2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, under section 250 of the Income-tax Act, 1961:

The appellant craves leave to add, amend, alter or delete the above Grounds of Appeal.”

We have heard both the side and have perused the material on record.

The Assessee is a charitable trust engaged in the educational activities which includes granting of scholarships to the students. For the Assessment Year 2016-17, assessment was framed on the Assessee vide Assessment Order, dated 10/12/2018. The Assessing Officer disallowed the income amounting to INR.62,28,989/- accumulated under Section 11(2) of the Act holding that the purpose stated for accumulation [i.e. “towards the object of the trust