ST. ANGELS SHIKSHA VIKAS SAMITI,JAIPUR vs. ITO (EXEMPTION), WARD - 1, JAIPUR, JAIPUR
IN THE INCOME TAX APPELLATE TRIBUNAL
JAIPUR BENCHES ‘SMC’, JAIPUR
BEFORE Dr. MANISH BORAD, ACCOUNTANT MEMBER
आयकर अपील सं. /ITA No. 681/JPR/2025
िनधारण वष / Assessment Year: 2019-20
St. Angels Shiksha Vikas Samiti,
80, Kiran Vihar, Opp. Rajat Path,
Manyawas, New Sanganer Road,
Jaipur-302 020, Rajasthan
PAN-AAFAS7193A
Vs
ITO (Exemption),
Ward-1, Jaipur
Appellant
Respondent
Assessee by :
Shri Mukesh Khandelwal, C.A.
Revenue by :
Shri Gautam Singh Choudhary,
JCIT
Date of hearing
:
03.07.2025
Date of pronouncement
:
31.07.2025
आदेश/ORDER
PER DR. MANISH BORAD, ACCOUNTANT MEMBER :
This appeal at the instance of assessee is directed against the order passed by the Ld. CIT(A) National
Faceless Appeal Centre, (NFAC) Delhi u/s 250 of the Income-tax Act, 1961 dated 05.03.2025 which in turn is arising out of the Assessment Order u/s 144 r.w.s 144B of Act for A.Y. 2019-20 dated 20.09.2021. 2. At the outset Ld. Counsel for the assessee submitted that the assessee failed to appear before both the lower authorities and therefore prayed that the issues on merits may please be restored to the file of the Ld. Juri ictional
Assessing Officer for denovo adjudication.
St. Angels Shiksha Vikas Samiti
On the other hand Ld. DR supported the order of Ld. CIT(A).
I have heard rival contentions and perused the record placed before me. I observe that the assessee is a Educational Institution and running a school and return of income for A.Y. 2019-20 e-filed on 14.07.2020 declaring ‘NIL’ income. In the return, assessee has claimed exemption u/s.10(23C)(vi) of the Act. Notice u/s.142(1) of the Act issued on 19.01.2021 but the details were not submitted. Assessment completed on 20.09.2021 making addition of Rs.11,05,719/- computed at 12.5% of the gross receipts. Assessee filed appeal before Ld. CIT(A) but failed to furnish the relevant details. Now the assessee has filed the copy of Balance Sheet and income and expenses account alongwith the constitution of the appellant institute. Gross receipts are claimed to be from school fees received from the students. Considering the details filed before me, I am of the considered view that in the larger interest of justice and being fair to both the parties, the matter needs to be restored to the file of the Juri ictional Assessing Officer (JAO) for framing a denovo assessment after duly considering the details and submissions to be filed by the assessee. Needless to mention that proper opportunity of hearing shall be granted to the assessee. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Effective grounds of appeal raised by the assessee are allowed for statistical purposes. St. Angels Shiksha Vikas Samiti
In the result, appeal of the assessee is allowed for statistical purposes.
Order pronounced on this 31st day of July, 2025. (MANISH BORAD)
ACCOUNTANT MEMBER
जयपुर/Jaipur; दनांक / Dated: 31st July, 2025. Neeta
आदेश क ितिलिप अेिषत / Copy of the Order forwarded to:
1. अपीलाथ / The Appellant.
2. यथ / The Respondent.
3. The Pr. CIT concerned.
4. िवभागीय ितिनिध, आयकर अपीलीय अिधकरण, "SMC" बच,
जयपुर / DR, ITAT, "SMC" Bench, Jaipur.
5. गाड फाइल / Guard File.
आदेशानुसार / BY ORDER,
//// Senior Private Secretary
आयकर अपीलीय अिधकरण, पुणे / ITAT, Jaipur