ABHYUTHTHAN GRAM VIKAS MANDAL,SURAT vs. CIT EXEMPTION, AHMEDABAD

ITA 838/SRT/2025Status: DisposedITAT Surat19 February 2026AY 2018-19Bench: DR. B.R.R. KUMAR, VICE-PRESIDENT MS. SUCHITRA KAMBLE (Judicial Member)8 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s order, dismissing both the assessee's and the Revenue's appeals. It found that the trust's activities, primarily executing government contracts, constituted business and were not in the nature of general public utility or charitable activities as required for exemption.

What were the facts?

The assessee, a charitable trust, undertook irrigation projects. The Assessing Officer treated its activities as business, denied exemption under Section 11, and made additions for advances to a trustee and a difference in reported receipts. The CIT(A) deleted the addition for receipt difference but upheld the denial of exemption due to the trustee advance.

What were the issues?

Whether the trust's contract execution activities qualified as charitable under Section 2(15) for exemption under Section 11, and whether advances to a trustee violated Section 13.

Which sections of the Income-tax Act were involved?

Section 11,Section 13(1)(c),Section 13(1)(d),Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: DR. B.R.R. KUMAR, VICE-MS. SUCHITRA KAMBLE

For Appellant: Shri Suresh K. Kabra, CA
For Respondent: Shri Ajay Uke, Sr DR
Hearing: 23.01.2026Pronounced: 19.02.2026

Heard together (2 matters)

I.T.A. No. 838/SRT/2025
I.T.A. No. 902/SRT/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:

- These cross appeals are directed against the order dated 10.06.2025 passed by the Ld. Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [“Ld. CIT(A)”], under Section 250 of the Income-tax Act, 1961 (“the Act”) for Assessment Year 2018–19. Since both appeals arise out of the same order, they are heard together and disposed of by this consolidated order.

The order continues below.

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