“application of income”

Judicial DoctrinesDiversion vs ApplicationDiversion vs Application1,603 judgments

The decision most relied on for application of income is Maxopp Investment Ltd. v. CIT (402 ITR 640), cited in 1,596 judgments on BharatTax.

Leading authorities on application of income

Maxopp Investment Ltd. v. CIT

402 ITR 640 · 2018 · Supreme Court

1,596

citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT

328 ITR 81 · 2010 · High Court

1,183

citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

CIT v. Max India Ltd.

295 ITR 282 · 2007 · Supreme Court

1,162

citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

Godrej & Boyce Manufacturing Company Ltd. v. DCIT

394 ITR 449 · 2017 · Supreme Court

683

citing judgments

Expenditure can only be disallowed under Section 14A if the income is exempt and not part of the total income. The Assessing Officer must first record dissatisfaction with the assessee's accounts or computation before proceeding to make a disallowance under Section 14A or applying Rule 8D.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.

342 ITR 169 · 2012 · High Court

658

citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Olari Little Flower Kuries (P.) Ltd. v. UOI

440 ITR 26 · 2022 · High Court

614

citing judgments

The fee under Section 234E of the Income-tax Act cannot be levied for defaults in filing TDS statements committed prior to June 1, 2015, as the provision for its levy became effective only from that date.

Dilip N. Shroff v. JCIT

291 ITR 519 · 2007 · Supreme Court

565

citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya

216 ITR 660 · 1995 · High Court

511

citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing application of income

Nalanda Group of Management Education, Kolkata vs. ITO, Ward-1(1)Exemption, Kolkata

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 140/KOL/2024[2013-14]Status: DisposedITAT Kolkata06 Nov 2025AY 2013-14

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 11Section 11(1)(a)Section 11(4)Section 12ASection 143(3)Section 250

production of the necessary evidences. The Ld. AR further stated that a sum of ₹70,07,000/- was disallowed as application of income which was paid as commission/consultancy charges. The Trust earns income from education which is a charitable purpose and necessary evidences are in the possession of the assessee ... paid for the services rendered which were directly related to the income earned by the assessee and/or was to be treated as application of income. This being so, the order of the Ld. CIT(A) is hereby set aside and all the issues in this appeal are restored

Shri Leuva Patel Kelavani Mandal, Jetpur vs. CIT (Exemption), Ahmedabad

In the result, the appeal of the assessee is allowed, for statistical purposes

ITA 138/RJT/2025[2022-23]Status: DisposedITAT Rajkot04 Nov 2025AY 2022-23

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.138/Rjt/2025 ("नधा"रण वष" / Assessment Year: (2022-23) Shri Leuva Patel Kelavani Mandal Vs. Cit(Exemption), Room No.609, 6Th Floor, Aayakar 01, Shri Leuva Patel Kelavni, Jetpur (Guj) -360370, Bhavan, Nr. Sachin Tower, 100Ft Road, Anandnagar-Prahladnagar Road, Ahmedabad-380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aants5027Q (Appellant) (Respondent) Appellant By : Shri Sumit Shingala, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit(Dr) : 08/10/2025 Date Of Hearing Date Of Pronouncement : 04/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm:

For Appellant: Shri Sumit Shingala, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 12(1)(ac)Section 12ASection 12A(1)(ac)Section 13

being Hall fit for gatherings and small functions). (Audited Income & Expenditure A/cs. Submitted are kept at +Pg No. 89, 98, and 104). The application of income is in form of Salary Exp., Electricity Exp., Property Taxes, Exp. for Maintenance of Building, and Administrative Exp. Like Stationery, accounting, etc. (Annexure

Dy. Commissioner of Income Tax (Exemptions), Circle, Pune, Swargate vs. Dr D Y Patil Unitech Society, Pune

In the result, the appeal filed by the Revenue is dismissed

ITA 1391/PUN/2025[2013-2014]Status: DisposedITAT Pune04 Nov 2025AY 2013-2014

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14 Dcit (Exemption) Dr D Y Patil Unitech Society Circle, Pune Flat No.101, Shree Motisagar Vs. Apartment, G G Thakkar Road, S No.173A, Pune – 411001 Pan: Aabtd1482A (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 27-10-2025 Date Of Pronouncement : 04-11-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar, CIT-DR

Section 11Section 11(1)(a)Section 11(2)Section 143(2)Section 143(3)Section 147Section 148

Officer to allow the deduction u/s 11(1)(a) of the Act on 15% of the receipt of the trust and allow the application of income after the remaining amount by observing as under: 4 7. Aggrieved with such order of the Ld. Addl / JCIT(A), the Revenue ... gross receipts without appreciating that such accumulation is permissible only out of the income remaining after application of income. 2. On the facts and circumstances of the case, the Ld. CIT(A) erred in relying upon the decision of the Hon'ble ITAT, Pune in the case of Maharshi Karve

M/S. Rukmini Educational Charitable Trust, Bengaluru vs. Principal Commissioner of Income Tax, Central, Bengaluru

ITA 2109/BANG/2024[2022-23]Status: DisposedITAT Bangalore04 Nov 2025AY 2022-23

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

Section 12Section 12ASection 132Section 132(4)Section 143(3)

land advances, nor transferred the property in the name of the Trust for which advances w- taken, the same cannot be allowed as application of income in the books of account of asses+ 39 Similarly, for earlier and subsequent AYs also the assessee trust has diverted trust funr’ ‘the trustees

M/S. Rukmini Educational Charitable Trust, Bengaluru vs. Principal Commissioner of Income Tax, Central, Bengaluru

ITA 2107/BANG/2024[2016-17]Status: DisposedITAT Bangalore04 Nov 2025AY 2016-17

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

Section 12Section 12ASection 132Section 132(4)Section 143(3)

M/S. Rukmini Educational Charitable Trust, Bengaluru vs. Principal Commissioner of Income Tax, Central, Bangalore

ITA 2106/BANG/2024[2015-16]Status: DisposedITAT Bangalore04 Nov 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Respondent byFor Respondent: Date of hearing

Section 12Section 12ASection 132Section 132(4)Section 143(3)

land advances, nor transferred the property in the name of the Trust for which advances wr taken, the same cannot be allowed as application of income in the books of account of assess 3.9 Similarly, for earlier and subsequent AYs also the assessee trust has diverted trust funt the trustees

ACIT(E), Lucknow vs. M/S. Bhagwant Institute of Technology, Bijnor

ITA 219/LKW/2020[2013-14]Status: DisposedITAT Lucknow31 Oct 2025AY 2013-14

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.219/Lkw/2020 निर्धारण वर्ष/ Assessment Year: 2013-14 Acit (Exemptions) V. M/S. Bhagwant Institute Of Technology T. C. 46V, 5Th Floor, U.P.S.I.D.C Ltd., Vibhutikhhand, Gomti Nagar, Lucknow-226001. Avas Vikas Coloney, Bijnor-243001. Pan:Aaatb4195M अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कि और से/Appellant By: Shri R. K. Agarwal Cit(Dr) प्रत्यर्थी कि और से /Respondent By: Shri Vinod Kumar, Ca सुनवाई कि तारीख / Date Of Hearing: 05 08 2025 घोषणा कि तारीख / Date Of Pronouncement: 31 10 2025 आदेश / O R Der Per Kul Bharat.: This Appeal, By The Revenue, Is Directed Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-Moradabad Dated 17.03.2020, Pertaining To The Assessment Year 2013-14. The Revenue Has Raised The Following Grounds Of Appeal: “1. Ld. Commissioner Of Income Tax (A) Has Erred In Law & Facts By Allowing The Benefit Of Section 11 Thereby Deleting The Addition Of Rs.2,66,94,072/- In The Form Of Admission & Smart Card Fees, Exam Fee, Fee Receipts, Projects Fees, Uniform Fees, Internet Fees & Book Bank Receipts From The Students Beyond The Prescribed Amount Of Fees As Decided By The Govt. Authorities, Which Clearly Indicates That The Objects Of The Assessee Are Not Charitable; 2. Ld. Commissioner Of Income Tax (A) Has Erred In Law & Facts In Deleting The Addition/Disallowance Of Rs.37,55,277/- Ignoring The Fact That The Assessee Could Not Substantiate It'S Claim With Documentary Evidences

For Appellant: Shri R. K. Agarwal CIT(DR)For Respondent: Shri Vinod Kumar, CA

Section 11Section 143(2)

आयकर अपीलीय अधिकरण 'ए' न्यायपीठ, लखनऊ। IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “A”, LUCKNOW श्री कुल भारत, उपाध्यक्ष

Shri Swami Samarth Adhyatmik Sanshodhan Sanstha, Aurangabad vs. CIT(E), Pune

In the result, the appeal filed by the assessee is allowed

ITA 98/PUN/2025[2025-26]Status: DisposedITAT Pune31 Oct 2025AY 2025-26

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri S.K. SethiFor Respondent: Shri Amit Bobde

Section 80GSection 80G(5)Section 80G(5)(ii)

objects of the assessee, as discussed above, are religious in nature and thus the instrument under which the assessee is constituted provide for application of income other than charitable purposes. 10. Considering the above facts discussed, conditions laid down under clause (ii) of sub-section (5) of Section

Om J J Swa Vishwashanti Dham Nirman Sanstha, Verul vs. ITO Exemption Ward, Aurangabad

In the result, appeal of the Assessee is allowed for statistical

ITA 2090/PUN/2025[2015-16]Status: DisposedITAT Pune31 Oct 2025AY 2015-16

Section 11Section 12ASection 143(1)Section 250

without prejudice to any other ground, the CPC has grossly erred in taxing the gross receipts of the appellant without considering the corresponding application of income and expenses and without prejudice to the other grounds, even if any addition was warranted, the same ought to have been restricted

Bible Fellowship Centre Wagholi, Pune vs. ITO, Exemption, Ward-1(2), Pune

In the result, appeal filed by the assessee is allowed as per the terms indicated above

ITA 1887/PUN/2025[2016-17]Status: DisposedITAT Pune31 Oct 2025AY 2016-17

Bench: Dr.Manish Borad

For Appellant: Shri B.C. MalakarFor Respondent: Shri Manoj Tripathi

Section 11Section 11(1)(a)Section 139(1)Section 143(2)Section 143(3)Section 80G

filing portal ld. AO did not found Form 9A and thus declined the claim. Further, ld. AO observed that assessee has claimed application of income of Rs.4,82,850/- u/s.11(1)(a) of the Act but since the Audit Report on Form No.10B was not furnished before the due date ... view of CBDT Circular No.07/2018 dated 20.12.2018 such delay ought to have been condoned and the claim of deemed application of income deserves to be allowed. Reference also made to the various documents placed in the paper book running into 66 pages. 7. On the other hand, ld. Departmental Representative

Rajya Vokkaligara Sangha, Bangalore vs. Additional Commissioner of Income Tax(Exemptions), Bangalore

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 815/BANG/2025[2013-14]Status: DisposedITAT Bangalore31 Oct 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Bharath L, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 11Section 12ASection 143(2)

university fee payable amounting to Rs.51,49,0399/- and for purchase of land of Rs.1,57,90,500/- AO did not consider as application of income. The learned CIT(A) confirmed addition made by the AO and against Order of learned CIT(A) assessee filed appeal before the Tribunal

Rajya Vokkaligara Sangha, Bangalore vs. Additional Commissioner of Income Tax(Exemptions), Bangalore

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 814/BANG/2025[2011-12]Status: DisposedITAT Bangalore31 Oct 2025AY 2011-12

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Bharath L, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 11Section 12ASection 143(2)

Shri Chintamani Parshwanath Shwetambar Murtipujak Jain Sangh, Mumbai vs. Exem. Ward 2(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 5038/MUM/2025[2023-24]Status: DisposedITAT Mumbai31 Oct 2025AY 2023-24

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri J. Kala, CAFor Respondent: Shri Virbhadra Mahajan, Sr. DR

Section 11Section 11(2)Section 11(2)(a)Section 11(3)Section 115BSection 12ASection 143(1)

clause (v) or sub-clause (V) or sub-clause (via) of clause (23C) of section 10, shall not be treated as application of income for charitable or religious purposes, either during the period of accumulation or thereafter. (3) Any income referred to in sub-section (2) which- (a) is applied ... clause (v) or sub-clause (vi) or sub-clause (via) of clause (23C) of section 10, shall not be treated as application of income for charitable or religious purposes, either during the period of accumulation or thereafter. (3) Any income referred to in sub-section (2) which- (a) is applied

Sacred Heart Church, Mumbai vs. Income Tax Officer Exemption Ward 2(3), Mumbai

In the result, grounds of appeal raised by assessee are allowed for statistical purpose

ITA 3790/MUM/2025[2024-25]Status: DisposedITAT Mumbai31 Oct 2025AY 2024-25

Bench: Shri Pawan Singh& Smt Renu Jauhri(Physical Hearing) Sacred Heart Church, Ito (Exemption) Ward-2(3), S.V. Road, Santacruz, Vs Mumbai, Mumbai – 400054. [Pan: Aabts 8974 L] Appellant / Assessee Respondent / Revenue

Section 11Section 12ASection 254(1)

assessee has raised multiple ground of appeal, however, in our considered view, the substantial ground of appeal relates to denial of relief on application of income under section 11 of Income Tax Act, for want of delay in filing Form-10B, rest of the grounds of appeal are consequential ... filing return of income on the same date. The assessing officer / Central Processing Centre (CPC) while processing the return of income not allowed application of income under section 11. The ld. AR of the assessee submits that there are series of decision by Tribunal and High Courts wherein

R. Mangaldas Charitable Trust, Mumbai vs. CIT(Exemption), Mumbai

In the result, the appeal of assessee is allowed

ITA 17/MUM/2025[N.A ]Status: DisposedITAT Mumbai31 Oct 2025

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyr. Mangaldas Charitable Trust, Cit (Exemptions), A-82, Vishnu Baug, Room No. 601, 137, S.V. Road, Vs. 6Th Floor, Andheri (W), Cumballa Hills, Mumbai-400058. Mtnl Te Building, Pedder Road, Pan : Aaatr0606H Dr.Gopalrao Deshmukh Marg, Cumballa Hill, Mumbai-400026. (Appellant) (Respondent) For Assessee : Mr. Niraj Seth For Revenue : Shri Umashankar Prasad, Cit-Dr Date Of Hearing : 01-10-2025 Date Of Pronouncement : 31-10-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Exemptions)-Mumbai [„Ld.Cit(E)‟], Dated 19-11-2024, Rejecting The Assessee‟S Application Moved U/S. 80G(5)(Iii) Of The Income Tax Act, 1961 („The Act‟).

For Appellant: Mr. Niraj SethFor Respondent: Shri Umashankar Prasad, CIT-DR

Section 11Section 80GSection 80G(5)Section 80G(5)(iii)

abroad and such assistance will be given in India by assisting in Indian rupees to Indian students and, therefore, as far as application of income is concerned, the same will happens for educational purposes in India. It was submitted that in any case, the assessee-trust has not remitted ... satisfied, he can reject the same. This section does not refer to the activities in India or outside India. It refers to application of income for charitable or religious purposes in India as also with direction or order of the Board for application of income as aforesaid outside India. Reading

Mitra Parivar, Mumbai vs. CIT(Exemption), Mumbai

In the result, the appeal of assessee is allowed

ITA 16/MUM/2025[N.A]Status: DisposedITAT Mumbai31 Oct 2025

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharymitra Parivar, Cit (Exemptions), 301, Maganlal Kala, Room No. 601, Gulmohar Road No.1, Vs. 6Th Floor, Jvpd Extn. Cumballa Hills, Andheri (West), Mtnl Te Building, Pedder Road, Mumbai-400049. Dr.Gopalrao Deshmukh Marg, Pan : Aaatm5059M Cumballa Hill, Mumbai-400026. (Appellant) (Respondent) For Assessee : Mr. Niraj Seth For Revenue : Shri Umashankar Prasad, Cit-Dr Date Of Hearing : 01-10-2025 Date Of Pronouncement : 31-10-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Exemptions)-Mumbai [„Ld.Cit(E)‟], Dated 19-11-2024, Rejecting The Assessee‟S Application Moved U/S. 80G(5)(Iii) Of The Income Tax Act, 1961 („The Act‟).

For Appellant: Mr. Niraj SethFor Respondent: Shri Umashankar Prasad, CIT-DR

Section 11Section 80GSection 80G(5)Section 80G(5)(iii)

abroad and such assistance will be given in India by assisting in Indian rupees to Indian students and, therefore, as far as application of income is concerned, the same will happens for educational purposes in India. It 6 was submitted that in any case, the assessee-trust has not remitted ... satisfied, he can reject the same. This section does not refer to the activities in India or outside India. It refers to application of income for charitable or religious purposes in India as also with direction or order of the Board for application of income as aforesaid outside India. Reading

Agrasen Medical Relief & Research Society, Jaipur vs. ITO(E), Ward-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1026/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1026/JPR/2025 निर्धरणवर्ष / AssessmentYear : 2016-17 Agrasen Medical Relief & Research Society Central Spine, Sector -7, Vidhyadhr Nagar Jaipur - 302 039 (Raj) बनाम Vs. अपीलार्थी / Appellant स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAATA 7540F The ITO (E) Ward - 1 Jaipur प्रत्यर्थी / Respondent निर्धारिती की ओरसे / Assesseeby :Shri P.C.Parwal, CA राजस्व की ओरसे /Revenue by: Shri Gautam Singh Choudh

For Appellant: Shri P.C.Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 11Section 12ASection 12A(1)(ac)Section 143(3)Section 194JSection 2(15)Section 80G

Before ld. CIT(A), the assessee claimed that even if corpus donation is considered as voluntary donation, still the application of income is more than 85% of the receipt (refer Pg 7 & 8 of CIT(A) order). The receipt of Rs.16,45,911/- is on account of medical services provided ... Total receipts as per Income & Expenditure Account 64,80,355 Corpus donation 30,19,100 Total receipts available for application 94,99,455 Application of income: - i. Revenue expenses as per I&E A/c 62,37,417 excluding depreciation ii. Capital expenditure as per Fixed assets 21,09,490 schedule

P D Memorial Trust, Delhi vs. Dlc-Ca-2, Range- 48, Ward Exemp 2(4), Delhi

In the result, the appeal of the assessee is allowed

ITA 3784/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 11Section 11(1)(d)Section 12ASection 139Section 139(1)Section 139(9)Section 143(1)

Appeals), has erred in not allowing revenue expenditure of Rs. 24,47,44,963/- and capital expenditure of Rs. 22,05,47,867/as application of income. 5. That the learned Commissioner of Income Tax (Appeals), has erred in not adjudicating the ground nos. 3 and 4 raised before

Koolking Foundation, Malerkotla vs. The Commissioner of Income Tax (Exemptions), Chandigarh

In the result, the appeal of the Assessee stands allowed for statistical purposes

ITA 882/CHANDI/2025[Not Applicable]Status: DisposedITAT Chandigarh29 Oct 2025

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 882 /Chd/2025 U/S 12Aa Kookling Foundation, The Cit बनाम C/O Kookling Udhyog Private (Exemptions), Limited, Chandigarh Vs. Village Ratolan, Focal Point, Dhuri Road, Malerkotla 148023 "थायी लेखा सं./ Pan No: Aaftk7048D अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Pankaj Bhalla, Ca (Virtual) राज"व क" ओर से/ Revenue By : Sh. Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 28.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 29.10.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 26.05.2025 Passed By The Ld. Commissioner Of Income Tax, Exemptions, Chandigarh.

For Appellant: Sh. Pankaj Bhalla, CA (Virtual)For Respondent: Sh. Manav Bansal, CIT DR

Section 124Section 12ASection 2(15)

without giving the assessee an opportunity to rebut such assumptions. 10. That the Ld. CIT (Exemptions) has acted beyond jurisdiction in examining the application of income or operational activities in detail at the stage of application under Section 12A, which is premature and beyond the scope of inquiry at initial

Rural Development Foundation, Anand vs. CPC, Bengaluru Juris. AO- the ITO, Ward-Exemption, Vadodara

In the result, the appeal of the assessee is allowed

ITA 927/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.927/Ahd/2025 िनधा"रण वष" /Assessment Year : 2019-20 Rural Development Cpc, Bengaluru बनाम/ Foundation Juris.Ao – The Ito Ward- V/S. Aitc, 2Nd Floor Exemption Narayan Complex Vadodara – 390 007 Nr.Shubh Laxmi Shopping Centre Station Road Anand – 388 001 "थायी लेखा सं./Pan: Aabtr 1090 C (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Ms. Arti N. Shah, Ar Revenue By : Shri Rameshwar P. Meena, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/10/2025 घोषणा की तारीख /Date Of Pronouncement: 29/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: 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 21/02/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2019-2020. 2. The Assessee Has Raised The Following Grounds Of Appeal: Rural Development Foundation Vs. Cpc, Bengaluru Juris Ao The Ito, Ward-Exemption Asst. Year : 2019-20

For Appellant: Ms. Arti N. Shah, ARFor Respondent: Shri Rameshwar P. Meena, Sr.DR

Section 11Section 12ASection 12A(1)(b)Section 143(1)Section 154Section 250

raised a demand of Rs. 63,13,848/- after disallowing the expenditure of Rs. 1,13,37,985/- claimed by the assessee as application of income for charitable purposes. Rural Development Foundation vs. CPC, Bengaluru Juris AO The ITO, Ward-Exemption Asst. Year : 2019-20 3.1. Subsequently, the assessee filed