VATVA INDUSTRIES ASSOCIATION CHARITABLE TRUST,AHMEDABAD vs. I.T.O. WARD 2 EXEMPTION , AHMEDABAD

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ITA 760/AHD/2025Status: DisposedITAT Ahmedabad25 February 2026AY 2020-21Bench: Shri Sanjay Garg, Judicial Member And Annapurna Gupta (Accountant Member)3 pages
AI SummaryAllowed

What did the Tribunal hold?

Upon clarification, the CPC admitted a calculation mistake and confirmed that the assessee's trust was duly registered under Section 12A(a) of the Act. Consequently, the Tribunal held that the disallowance made by the lower authorities was not sustainable and ordered its deletion.

What were the facts?

The assessee, Vatva Industries Association Charitable Trust, filed an appeal against the CIT(A)'s order for AY 2020-21, alleging a calculation mistake by the CPC. The CPC had disallowed the exemption claimed under Section 11, citing the assessee's failure to furnish Section 12A registration details. The Tribunal sought clarification from the AO/CPC regarding the alleged mistake and disallowance.

What were the issues?

Whether the disallowance of exemption under Section 11 by the CPC due to an alleged calculation mistake and non-furnishing of Section 12A registration details was justifiable.

Which sections of the Income-tax Act were involved?

Section 250,Section 11,Section 12A,Section 12A(a)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC” BENCH, AHMEDABAD

Before: Shri Sanjay Garg & Annapurna Gupta

For Appellant: Shri Jainish Parikh, AR
Hearing: 19/02/2026Pronounced: 25/02/2026

Year : 2020-21 Vatva Industries Association The I.T.O. बनाम/ Charitable Trust Ward-2 Exemption v/s. Phase-I, Ahmedabad – 380 015 Nr. Old Nirma B/h. SBI Vatva Ahmedabad – 382 445 "थायी लेखा सं./PAN: AAATV 1541 M (अपीलाथ*/ Appellant) (+, यथ*/ Respondent) Assessee by : Shri Jainish Parikh, AR Revenue by : Shri Suresh Chand Meena, Sr.DR सुनवाई की तारीख/Date of Hearing : 19/02/2026 घोषणा की तारीख /Date of Pronouncement: 25/02/2026 आदेश/O R D E R

Per Sanjay Garg, Judicial Member:

1.

The present appeal has been preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘CIT(A)’] dated 12/02/2025 passed u/s.250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the Assessment Year (AY) 2020-21.

2.

In this appeal, the assessee had alleged that there was a calculation mistake on the part of the CPC while assessing the income of the assessee. In Vatva Industries Association Charitable Trust vs. ITO Asst. Year : 2020-21 this regard, the Tribunal had sought clarification through the Ld. DR from the AO/CPC, in response to which the following reply has been received:

“2. In this case, earlier para wise reply in the case of Vatva Industries Association Charitable Trust bearing ITA NO, 760/Ahd/2025 for AY 2020-21 was forwarded on 21.11.2025. As regards to the query to provide explanation as to why the calculation in the schedules and the final calculation of Income does not match, it was mentioned that a ticked has been raised to CPC to provide the solution which was awaited. Now, CPC has given the reason for demand. Revised comments after considering reply of CPC is as under:

Sl.No. Objection Remark 1. The AO to recheck the On perusal of records, it is noticed that the calculation made by the calculation made by the CPC is incorrect and CPC this apparent from records. As the records, the CPC wrongly disallowed the exemption claimed u/s 11 of the act by the assessee.

2. Provide an explanation Calculation is made by CPC, In this regard, as to why the calculation CPC has replied that "As verified return in the schedules and the process with Demand Reason for Demand: final calculation of As Tax payer has not provided Income doesn’t match registration details exemption is disallowed.”

However, on perusal of record, it is gathered that assessee trust is duly registered u/s 12A(a) of the Act vide order no, HQ.III/X- 32/V-45/76/AR.IV dated 09.05.1977 by the then authority the CIT, Gujarat-III, Ahmedabad. (Copy of CPC reply and certificate is enclosed herewith for reference.

4.

Submitted for kind perusal and further direction.”

3.

On perusal of the above reply, it reveals that the entire expenditure of the assessee has been disallowed by the CPC as the assessee allegedly had not furnished the registration details u/s.12Aof the Act. However, in the clarification, it has been admitted that there was calculation mistake and further that the registration of the assessee u/s.12A of the Act has been duly Vatva Industries Association Charitable Trust vs. ITO Asst. Year : 2020-21 verified. In view of this, the disallowance made by the lower authorities is not sustainable, the same is ordered to be deleted.

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