SARVODAYA SAMAJ KALYAN SANSTHAN,JAMUI vs. CPC , BANGALURU

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ITA 563/PAT/2024Status: DisposedITAT Patna26 November 2025AY 2018-2019Bench: SHRI SONJOY SARMA (Judicial Member), SHRI RAKESH MISHRA (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee, being an institution solely existing for educational purposes and having gross receipts below Rs. 1 crore, qualifies for exemption under Section 10(23C)(iiiad) of the Income Tax Act. Therefore, the assessment at MMR was not justified.

What were the facts?

The assessee, an educational trust, filed its return of income for AY 2018-19 declaring a surplus. The income tax intimation charged tax at the Maximum Marginal Rate (MMR) instead of normal slab rates. The assessee's rectification petitions were rejected, and an appeal to the CIT(A) was also dismissed.

What were the issues?

Whether the assessee, an educational trust, is eligible for exemption under Section 10(23C)(iiiad) and whether charging tax at Maximum Marginal Rate is justified.

Which sections of the Income-tax Act were involved?

Section 250,Section 143(1),Section 154,Section 11,Section 12AA,Section 2(15)

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Income Tax Appellate Tribunal, KOLKATA-PATNA ‘e-COURT’, KOLKATA

Before: SHRI SONJOY SARMA & SHRI RAKESH MISHRA

For Respondent: Shri Ashwani Kr. Singal, JCIT

Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER ITA No.: 563/PAT/2024 Assessment Year: 2018-19 Sarvodaya Samaj Kalyan CPC, Bangaluru Sansthan Vs. (Appellant) (Respondent) PAN: AAEAS1257L Appearances: Assessee represented by : N o n e Department represented by : Shri Ashwani Kr. Singal, JCIT Date of concluding the hearing : 13-October-2025 Date of pronouncing the order : 26-November-2025 ORDER

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