INCOMETAX OFFICER EXEMPTIONS WARD, TIRUNELVELI vs. THE CHRISTIAN BUSINESSMEN EDUCATIONAL FELLOWSHIP, KOVILPATTI

ITA 2395/CHNY/2025Status: DisposedITAT Chennai19 January 2026AY 2019-20Bench: HON’BLE SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The CIT(A) held that the adjustment made under section 143(1) was beyond jurisdiction, deleted the disallowance, and quashed the demand. The Tribunal upheld the CIT(A)'s order, finding that the disallowance was not a mere arithmetical error but involved substantive examination of the assessee's claim, which is not permissible in summary proceedings.

What were the facts?

The assessee, a registered charitable society running an educational institution, filed its return for AY 2019-20 declaring NIL income. The CPC processed the return under section 143(1) and disallowed revenue expenditure of Rs. 5,10,46,521/-, leading to a tax demand of Rs. 2,13,54,603/-. Subsequent rectification petitions were also rejected.

What were the issues?

Whether the disallowance of revenue expenditure made by CPC under section 143(1) for alleged inconsistency in schedules was beyond its jurisdiction.

Which sections of the Income-tax Act were involved?

Section 12A,Section 80G,Section 11,Section 143(1),Section 154,Section 143(1)(a)(ii),Section 11(5),Section 13

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Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: HON’BLE SHRI MANU KUMAR GIRI & SHRI S.R. RAGHUNATHA

Hearing: 07.01.2026Pronounced: 19.01.2026

PER MANU KUMAR GIRI, JUDICIAL MEMBER:

The captioned appeal filed by the Revenue is directed against order of the Ld. Commissioner of Income Tax (Appeal), ADDL/JCIT (A) Ranchi [‘CIT(A)’ in short] dated 26.06.2025 for Assessment Year 2019-20. :- 2 -:

2.

Brief facts of the case are that the assessee is a registered charitable society, holding val

The order continues below.

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