RAMJIDAS BUDHRAJA CHARITABLE TRUST (SGM),CHHINDWARA vs. INCOME TAX OFFICER EXEMPTION, JABALPUR

ITA 235/JAB/2025Status: DisposedITAT Jabalpur19 February 2026AY 2015-16Bench: SHRI KUL BHARAT (Vice President), SHRI ANADEE NATH MISSHRA (Accountant Member)14 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that proceedings under Section 147 are for the benefit of the Revenue and not the assessee. Therefore, a claim not made in the return of income or during assessment proceedings cannot be allowed for the first time in appeal.

What were the facts?

The assessee, a charitable trust, claimed a deduction for accumulation of income under Section 11(2) of the Income Tax Act. This claim was not made in the original return of income and was first raised during appellate proceedings.

What were the issues?

Whether a claim for deduction under Section 11(2) can be allowed for the first time in appellate proceedings when the assessment was initiated under Section 147.

Which sections of the Income-tax Act were involved?

Section 11(2),Section 147,Section 148

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Cases cited in this judgment(5)Show list

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Income Tax Appellate Tribunal, JABALPUR BENCH “DB”, JABALPUR

Before: SHRI KUL BHARAT & SHRI ANADEE NATH MISSHRA

For Appellant: Shri G. N. Purohit, Advocate

PER ANADEE NATH MISSHRA: A.M. (A) This appeal vide I.T.A. No.235/JBP/2025 has been filed by the assessee for assessment year 2015-16 against impugned appellate order dated 14.07.2025 (DIN & Order No.ITBA/APL/S/250/2025- 26/1078443117(1) of Ld. Addl/JCIT Commissioner of Income Tax (Appeals), the First Appellate Authority. The grounds of appeal are as under:

“1. The learned CIT appeal has erred in law and on facts of the case, in not permitting the claim of deduction for accumulation of income of rupees 39,00,000/- under section 11(2) of the Income Tax Act. Necessary compliance as per rules was made by the assessee, and form number 10 was submitted before the assessing officer wi

The order continues below.

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