GAYATRI SHIKSHA NYAS,AGRA vs. ITO (EXEMPTION), AGRA, AGRA

ITA 520/AGR/2025Status: DisposedITAT Agra16 February 2026AY 2017-18Bench: SHRI S. RIFAUR RAHMAN (Accountant Member)6 pages
AI SummaryRemanded

What did the Tribunal hold?

The ITAT condoned the substantial delay in filing the appeal before the CIT(A) and also a 10-day delay before the ITAT, considering the assessee's charitable activities and the interest of substantial justice. The matter was remitted back to the CIT(A) for adjudication on merits, with directions for both parties to cooperate.

What were the facts?

The assessee, an educational trust, filed its return of income, which was processed under Section 143(1) of the Income Tax Act, treating voluntary contributions as income under Section 11(1)(d). The assessee's rectification application under Section 154 was rejected, leading to a significant delay of 2350 days in filing an appeal before the CIT(A), which was subsequently dismissed due to the delay.

What were the issues?

The key legal issues were the condonation of a significant delay in filing an appeal before the CIT(A) and whether voluntary contributions to an educational trust should be exempt under Section 10(23C)(iiiad) instead of being taxed under Section 11(1)(d).

Which sections of the Income-tax Act were involved?

Section 143(1),Section 154,Section 11(1)(d)

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Income Tax Appellate Tribunal, AGRA (SMC

Before: SHRI S. RIFAUR RAHMAN

Hearing: 16.02.2026Pronounced: 16.02.2026

Both these appeals have been filed by assessee against separate orders of the learned Commissioner of Income-tax (Appeals) -4, Chennai dated 29.08.2025 & 16.09.2025 for the Assessment Years 2016-17 & 2017-18. 2. Since the issues involved in both these appeals are similar, the same were heard together and are being disposed of by this consolidated order for the sake of convenience and brevity. We take up ITA No. 513/Agr/2025 as a lead case.

ITA No.513 & 520/Agr/2025

3.

In the ITA No. 513/Agr/2025, aggrieved with the above order, assessee is in appeal before ITAT, raising following grounds of appeal :

1.

That the learned CIT(A) erred in law and on facts in dismissing the appeal solely on the ground of delay of 2350 days, without

The order continues below.

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