ITAT Jodhpur Judgments — April 2025

The Tribunal held that the CIT(A) was justified in deleting the addition. It found that the assessee's books of accounts were maintained regularly and audited under various laws. The AO's allegations regarding the non-maintenance of stock registers and an absurd computation of bogus sales based on a human probability test were not supported by evidence. The revenue failed to controvert the evidence produced by the assessee to substantiate the cash deposits.

The Tribunal held that the CIT (Exemption) acted in a hurried and irrational manner by rejecting the application solely based on the pending RPT Act registration, which was subsequently granted. The genuineness of activities is also not relevant at this stage.

The Tribunal found that the CIT had not considered the amended trust deed and documentary evidence properly. It held that the activities, including running a Dharamshala, were for public welfare and not restricted to a particular community.

The Tribunal found that the CIT had not considered the amended trust deed and documentary evidence properly. The Tribunal set aside the CIT's order and restored the matter for fresh examination.

The Tribunal held that the AO conducted detailed inquiries and was satisfied with the genuineness of the agricultural income claim, adopting a plausible view. Therefore, the revisionary proceedings under Section 263 were quashed.

The Tribunal held that Section 115BBC is not applicable to the assessee's case as it caters to religious and charitable purposes and falls under the exceptions. The Tribunal also allowed the claim for construction of the university building and purchase of books as application of income.