SHRI MULTANCHAND BORA TRUST,PUNE vs. ACIT, EXEMPTION, CIRCLE- AURANGABAD, AURANGABAD

ITA 1312/PUN/2025Status: DisposedITAT Pune09 December 2025AY 2020-21Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the CIT(Exemption)'s observation regarding donations being corpus donations was factually incorrect as the receipts did not specify corpus. However, the Tribunal found that the CIT(Exemption)'s concern regarding the utilization of accumulated income within the prescribed period was valid, as the AO had not adequately verified this aspect.

What were the facts?

The assessee trust challenged a revisionary order under Section 263 of the Income Tax Act. The CIT(Exemption) had set aside the assessment order, alleging lack of inquiry into donations and accumulation of income. The assessee argued that the Assessing Officer had conducted sufficient inquiry and had all necessary documents.

What were the issues?

Whether the CIT(Exemption) correctly exercised revisionary powers under Section 263 when the Assessing Officer had conducted inquiries regarding donations and accumulation of income.

Which sections of the Income-tax Act were involved?

Section 263,Section 11(2),Section 11(3)

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Income Tax Appellate Tribunal, PUNE BENCHES “B” :: PUNE

Before: DR.DIPAK P. RIPOTE & SHRI VINAY BHAMORE

For Appellant: Shri Shrenik Gandhi
For Respondent: Shri Amit Bobde –CIT(DR)
Hearing: 11/09/2025Pronounced: 09/12/2025

PER DR. DIPAK P. RIPOTE, AM: This appeal is filed by the Assessee against the order of ld.Commissioner of Income Tax(Exemption), Pune at Nashik passed under section 263 of the Income Tax Act, 1961 for A.Y.2020-21, dated 30.03.2025 emanating from Assessment Order u/s.143(3) of the I.T.Act, dated 20.09.2022. The assessee has raised following grounds of appeal :

“1. Ground No. 1: The Learned CIT (Exemption) seriously erred on the facts and law, in exercising the revisionary powers under Section ITA No.1312/PUN/2025 [A] 263 of the Income-tax Act, 1961 (“IT Act”) and without satis

The order continues below.

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