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“anonymous donation”

Charitable TrustsSection 115BBCSection 115BBC175 judgments

The decision most relied on for anonymous donation is CIT v. Halai Namon Association ( (330 ITR 24), cited in 33 judgments on BharatTax.

Leading authorities on anonymous donation

CIT v. Halai Namon Association (
330 ITR 24 · 2011 · High Court
33
citing judgments

Profits generated from activities for the advancement of a general public utility (GPU) do not automatically qualify for exemption under Section 11 if the GPU is carried on as a business. Even if business profits are reinvested into charitable activities, the exemption under Section 11 will not be available.

CIT & Another v. MBA Nahata Charitable Trust
364 ITR 693 · Reported
14
citing judgments

Exemption under section 11 of the Income-tax Act is allowable for charitable trusts even if donations are anonymous, provided the amounts are spent towards charitable objects.

(a) DIT(E) v Keshav Social and Charitable Foundation (2005) 278 ITR 152 (Del) (b) CIT v. Uttaranchal Welfare Society
364 ITR 398 · 2014 · High Court
11
citing judgments

Section 68 of the Income-tax Act, 1961, does not apply to a sum that has already been offered as income or utilized for charitable purposes.

Judgments citing anonymous donation

St.Joseph'S Educational Trust, Chennai vs. PCIT Central Chennai - 1, Chennai

In the result, all the three appeals filed by the assessee are allowed

ITA 1620/CHNY/2024[2020-21]Status: DisposedITAT Chennai15 Oct 2024AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Nilay Baran Som, IRS, CIT
Section 11Section 115BSection 12ASection 142(1)Section 153ASection 153DSection 263

Trust St. Joseph Education Trust 2020-21 24,00,000 78,75,000 1,02,75,000 sheet as 'cash' were offered to tax "anonymous donations" and paid taxes thereon under section 115BBC of the Act. The seized material Ann/JCE/ANJ/ED/S-1 does not mention that the alleged receipts are capitation fees ... assessment passed u/s.153A r.w.s.144 of the Act dated 28.09.2021 and stated that the assessee has recomputed the total income treating the cash donations as anonymous donations and corpus donations collected in DD. The AO in his search assessment order u/s 153A r.w.s.144 in para 3 and 4 had noted

St.Joseph'S Institute of Science and Technology Trust, Chennai vs. PCIT Central Chennai - 1, Chennai

In the result, all the three appeals filed by the assessee are allowed

ITA 1619/CHNY/2024[2020-21]Status: DisposedITAT Chennai15 Oct 2024AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Nilay Baran Som, IRS, CIT
Section 11Section 115BSection 12ASection 142(1)Section 153ASection 153DSection 263

Trust St. Joseph Education Trust 2020-21 24,00,000 78,75,000 1,02,75,000 sheet as 'cash' were offered to tax "anonymous donations" and paid taxes thereon under section 115BBC of the Act. The seized material Ann/JCE/ANJ/ED/S-1 does not mention that the alleged receipts are capitation fees ... assessment passed u/s.153A r.w.s.144 of the Act dated 28.09.2021 and stated that the assessee has recomputed the total income treating the cash donations as anonymous donations and corpus donations collected in DD. The AO in his search assessment order u/s 153A r.w.s.144 in para 3 and 4 had noted

St.Joseph'S Institute of Science and Technology Trust, Chennai vs. PCIT Central Chennai - 1, Chennai

In the result, all the three appeals filed by the assessee are allowed

ITA 1618/CHNY/2024[2018-19]Status: DisposedITAT Chennai15 Oct 2024AY 2018-19
Section 11Section 115BSection 12ASection 142(1)Section 153ASection 153DSection 263

Nos.1618 to 1620/Chny/2024 The assessee have duly offered those receipts which were mentioned in the excel sheet as 'cash' were offered to tax "anonymous donations" and paid taxes thereon under section 115BBC of the Act. The seized material Ann/JCE/ANJ/ED/S-1 does not mention that the alleged receipts are capitation fees ... assessment passed u/s.153A r.w.s.144 of the Act dated 28.09.2021 and stated that the assessee has recomputed the total income treating the cash donations as anonymous donations and corpus donations collected in DD. The AO in his search 8 ITA Nos.1618 to 1620/Chny/2024 assessment order u/s 153A r.w.s.144 in para

New Life Fellowship Trust, Gurgaon vs. ITO (E), Faridabad

In the result, appeal of the assessee is allowed

ITA 5295/DEL/2019[2015-16]Status: DisposedITAT Delhi15 Oct 2024AY 2015-16

Bench: Pradip Kumar Kedia & Shri Vimal Kumarnew Life Fellowship Trust Vs. Ito(Exemption) S-358, Gf Uppal’S South End Faridabad Sohna Road Gurugram – 122018 Pan No. Aaatn 9270 B (Appellant) (Respondent) Assessee By Shri Alok Kumar Gupta, Adv. Revenue By Shri Pramod Kumar, Sr. D.R. Date Of Hearing: 15.10.2024 Date Of Pronouncement: 15.10.2024 Order Per Pradip Kumar Kedia, Am : The Captioned Appeal Has Been Filed At The Instance Of The Assessee Against The First Appellate Order Passed By The Commissioner Of Income Tax (Appeals)- Faridabad (‘Cit(A)’ In Short) Dated 31.03.2019 Arising From The Assessment Order Dated 19.06.2017 Passed By The Assessing Officer (Ao) Under Section 143(3) Of The Income Tax Act, 1961 (‘The Act’) Concerning A.Y. 2015-16 In Question.

Section 11Section 12ASection 13(3)Section 143(2)Section 143(3)Section 251(1)(a)

with the CIT(A) has been invoked to make New Life Fellowship Trust vs. ITO A.Y. 2015-16 enhancement on account of certain alleged anonymous donations received by the Assessee Trust. 3. When the matter was called for hearing, the learned Counsel for the assessee submitted at the outset that ... before the CIT(A). However, the CIT(A) while granting relief on the issue raised, simultaneously observed that certain receipts by way of alleged anonymous donations have been received by the assessee trust during the year as discussed in para 7 of the First Appellate order. The CIT(A) examined

Inst of Tool Room Trg Up, Lucknow vs. ITO, NFAC, Lucknow

In the result, the appeal is partly allowed for statistical purposes

ITA 332/LKW/2024[2018-19]Status: DisposedITAT Lucknow26 Sept 2024AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 143(3)Section 253(3)

returned income of nil. The addition made by the Assessing Officer was on I.T.A. No.332/Lkw/2024 Assessment year:2018-19 3 account of voluntary and anonymous donations received by the assessee. The assessee filed appeal in the office of learned CIT(A) against the aforesaid impugned assessment order dated 12/04/2021. Vide

Adivasi Unnati Seva Mandal, Rajur District Ahmednagar vs. Asstt. Commissioner of Income Tax Exemption Circle, Aurangabad

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

ITA 948/PUN/2023[2017-18]Status: DisposedITAT Pune23 Sept 2024AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Ramnath P Murkunde
Section 115BSection 133(6)Section 143(3)Section 270ASection 270A(9)(d)

total donation or Rs.1 lakh, whichever is higher, the Assessing Officer brought to tax an amount of Rs.44,75,190/- as anonymous donation for taxation u/s 115BBC of the Act, by observing as under: 2 “4.1 To verify the identity and genuineness of the donors, letters u/s 133(6) were ... letter u/s 133(6), 40% of total donation of Rs. 1,27,86,243/- amounting to Rs.51,14,500/- are hereby treated as anonymous donation u/s 115BBC and accordingly taxed. Penalty proceedings u/s 270A(9)(d) are initiated separately for misreporting of income.” 3. Thereafter, the Assessing Officer initiated penalty

Vishal Mumbai Shikshan Prasarak Mandal, Mumbai vs. ITO(E) 2(4), Mumbai

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 237/MUM/2024[2014-15]Status: DisposedITAT Mumbai06 Sept 2024AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singh

For Appellant: Shri Piyush ChacheddFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 11(1)Section 11(2)Section 12ASection 139Section 142(1)Section 143(2)Section 250Section 271(1)(c)

details from the Banks. 4) The learned Commissioner of Income Tax (Appeals) erred in confirming the addition of Rs.13,28,370/- as anonymous donations and taxing at maximum marginal rate of tax in spite of the appellant having filed the names, addresses of these donors along with their

Vishal Mumbai Shikshan Prasarak Mandal, Mumbai vs. ITO(E) 2(4), Mumbai

In the result, both the appeals of the assessee are allowed for

ITA 236/MUM/2024[2015-16]Status: DisposedITAT Mumbai06 Sept 2024AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singh

Section 11(1)Section 11(2)Section 12ASection 139Section 142(1)Section 143(2)Section 250

details from the Banks. 4) The learned Commissioner of Income Tax (Appeals) erred in confirming the addition of Rs.13,28,370/- as anonymous donations and taxing at maximum marginal rate of tax in spite of the appellant having filed the names, addresses of these donors along with their

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2938/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Aug 2024AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2937/DEL/2023[2016-17]Status: DisposedITAT Delhi30 Aug 2024AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2936/DEL/2023[2015-16]Status: DisposedITAT Delhi30 Aug 2024AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2935/DEL/2023[2014-15]Status: DisposedITAT Delhi30 Aug 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI ANUBHAV

Saisham Bahuudheshiya Sanstha Dhule, Dhule vs. ITO Exemption Ward 2, Nashik

In the result, the appeal filed by the appellant trust is dismissed

ITA 1343/PUN/2024[2012-13]Status: DisposedITAT Pune26 Aug 2024AY 2012-13

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1343/Pun/2024 "नधा"रण वष" / Assessment Year : 2012-13

For Appellant: NoneFor Respondent: Shri Ratnakar Shelake
Section 115BSection 12ASection 143(3)Section 154Section 80G

year under consideration. Subsequently, the AO passed rectification of the assessment order vide order dated 30.12.2016 u/s.154 of the Act treating the donations as anonymous donations and brought to tax the same under the provisions of section 115BBC of the Act. The AO further noted that appellant trust is neither ... details filed by the appellant trust, such as names, addresses & PAN of the donors, the AO was justified in treating the entire donations as anonymous donations applying the provisions of section 115BBC of the Act. 7. I heard the ld. Sr. DR and perused the material on record. The solitary

Trimurti Pawan Pratisthan Versus, Ahmednagar vs. DCIT, Exem-Circle-2, Mumbai

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

ITA 51/MUM/2024[2017-18]Status: DisposedITAT Mumbai06 Aug 2024AY 2017-18

Bench: Shri Sandeep Singh Karhail & Smt. Renu Jauhri

For Appellant: Shri Bhupendra KarkhanisFor Respondent: Shri R. R. Makwana, Sr. DR
Section 115Section 115BSection 142(1)Section 143(2)Section 143(3)Section 250

Assessing Officer (“AO”) vide order dated 27/12/2019 passed under section 143(3) of the Act treated the donation of INR 26 lakh as anonymous donation and taxed the same under section 115 BBC of the Act. 5. In appeal before the learned CIT(A), the assessee submitted that

Chhedanagar Nagar Education Society, Mumbai vs. ITO, Exemption Ward 1(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1673/MUM/2024[2018-19]Status: DisposedITAT Mumbai31 Jul 2024AY 2018-19

Bench: SHRI B.R. BASKARAN (Accountant Member), SHRI SUNIL KUMAR SINGH ( (Judicial Member)

Section 11Section 12A

confirming the addition of Rs. 6.54 crores made by the Assessing Officer (AO) treating the above said amount as anonymous donations received by the assessee. 2. The facts relating to the case are stated in brief. The assessee is an Education Society registered under the Bombay Public Trust ... only. Accordingly, the AO treated the difference between the above said two figures, which amounted to Rs. 6,54,46,347/- as anonymous donation received by the assessee and added the same to the total income of the assessee. The Ld. CIT(A) also confirmed the same. Hence the assessee

Regal Education Society, Ratnagiri vs. Income Tax Officer (Exemptions), Kolhapur

In the result, three appeals of the assessee in ITA Nos

ITA 697/PUN/2024[2020-21]Status: DisposedITAT Pune30 Jul 2024AY 2020-21

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.695, 696 & 697/Pun/2024 िनधा"रण वष" / Assessment Years: 2018-19, 2020-21 Regal Education Society, The Income Tax 104, Swami Complex, V Officer(Exemptions), Bazarpeth, Chiplun, Ratnagiri, S Kolhapur. Maharashtra – 415605. Pan: Aabtr5097B Appellant Respondent Assessee By None. Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 30/07/2024 Date Of Pronouncement 30/07/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals), All Dated 04.03.2024 Passed U/Sec.250 Of The Act For A.Y.2018-19 & A.Y.2020-21. The Assessee In Ita No.695/Pun/2024 Has Raised The Following Grounds Of Appeal : 1. On The Facts & Circumstances Of The Case & In Law The Ld. Cit(A) Erred In Dismissing The Appeal Due To Delay In Filing Without Considering The Case On Merits.

Section 10Section 11Section 115BSection 12ASection 250Section 270A

corpus in the instant case for A.Y.2018-19 WAS Rs 21342421/-, five percent of the same i.e. Rs 10,67,121/- is being allowed as anonymous donation and the rest (Rs 2,02,75,300) is taxed at the maximum marginal rate.” 4. The assessee had filed elaborate submission before

Regal Education Society, Ratnagiri vs. Income Tax Officer (Exemptions), Kolhapur

In the result, three appeals of the assessee in ITA Nos

ITA 696/PUN/2024[2018-19]Status: DisposedITAT Pune30 Jul 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.695, 696 & 697/Pun/2024 िनधा"रण वष" / Assessment Years: 2018-19, 2020-21 Regal Education Society, The Income Tax 104, Swami Complex, V Officer(Exemptions), Bazarpeth, Chiplun, Ratnagiri, S Kolhapur. Maharashtra – 415605. Pan: Aabtr5097B Appellant Respondent Assessee By None. Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 30/07/2024 Date Of Pronouncement 30/07/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals), All Dated 04.03.2024 Passed U/Sec.250 Of The Act For A.Y.2018-19 & A.Y.2020-21. The Assessee In Ita No.695/Pun/2024 Has Raised The Following Grounds Of Appeal : 1. On The Facts & Circumstances Of The Case & In Law The Ld. Cit(A) Erred In Dismissing The Appeal Due To Delay In Filing Without Considering The Case On Merits.

Section 10Section 11Section 115BSection 12ASection 250Section 270A

corpus in the instant case for A.Y.2018-19 WAS Rs 21342421/-, five percent of the same i.e. Rs 10,67,121/- is being allowed as anonymous donation and the rest (Rs 2,02,75,300) is taxed at the maximum marginal rate.” 4. The assessee had filed elaborate submission before

Regal Education Society, Ratnagiri vs. Income Tax Officer (Exemptions), Kolhapur

In the result, three appeals of the assessee in ITA Nos

ITA 695/PUN/2024[2018-19]Status: DisposedITAT Pune30 Jul 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.695, 696 & 697/Pun/2024 िनधा"रण वष" / Assessment Years: 2018-19, 2020-21 Regal Education Society, The Income Tax 104, Swami Complex, V Officer(Exemptions), Bazarpeth, Chiplun, Ratnagiri, S Kolhapur. Maharashtra – 415605. Pan: Aabtr5097B Appellant Respondent Assessee By None. Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 30/07/2024 Date Of Pronouncement 30/07/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Three Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals), All Dated 04.03.2024 Passed U/Sec.250 Of The Act For A.Y.2018-19 & A.Y.2020-21. The Assessee In Ita No.695/Pun/2024 Has Raised The Following Grounds Of Appeal : 1. On The Facts & Circumstances Of The Case & In Law The Ld. Cit(A) Erred In Dismissing The Appeal Due To Delay In Filing Without Considering The Case On Merits.

Section 10Section 11Section 115BSection 12ASection 250Section 270A

corpus in the instant case for A.Y.2018-19 WAS Rs 21342421/-, five percent of the same i.e. Rs 10,67,121/- is being allowed as anonymous donation and the rest (Rs 2,02,75,300) is taxed at the maximum marginal rate.” 4. The assessee had filed elaborate submission before

DCIT, C-1, (E), Chandigarh vs. M/S Aryans Educational and Charitable Trust, Mohali

In the result, Revenue’s appeal is dismissed

ITA 880/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh25 Jul 2024AY 2014-15

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 880/Chd/2019 "नधा"रण वष" / Assessment Years : 2014-15 The Dcit, Vs. M/S Aryans Educational & बनाम Circle-1 (Exemptions), Charitable Trust, Chandigarh # 2129, Phase-X, Mohali "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/ Appellant ""यथ"/ Repsondent

For Appellant: Sh. Tej Mohan, Singh, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 11Section 11(3)Section 11(5)Section 12ASection 13Section 13(3)Section 13(3)(c)

year, exemption has been denied to the assessee on account of the same balance in Imprest account. That year another significant matter of bogus / anonymous donations was unearthed by the AO that led subsequently to withdrawal of exemption and consequent taxing of the entire surplus during that year

M/S Aryans Educational and Charitable Trust, Mohali vs. DCIT, C-1, (E), Chandigarh

In the result, the appeal of the Assessee is partly allowed

ITA 823/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh25 Jul 2024AY 2015-16

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 823/Chd/2019 "नधा"रण वष" / Assessment Years : 2015-16 M/S Aryans Educational & Vs. The Dcit, बनाम Charitable Trust, Circle-1 (Exemptions), # 2129, Phase-10, Chandigarh Mohali "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/ Appellant ""यथ"/ Repsondent

For Appellant: Sh. Tej Mohan, Singh, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 11(5)Section 12ASection 13Section 13(1)(c)Section 13(3)(c)

meant to be bled in order to favour its functionaries/office bearers. In that light and also infractions pointed earlier including the issue of anonymous donations (unsubstantiated donations) the AO is right in denying the exemption claimed by the assessee and taxing the surplus amount. The assessee has clearly deviated ... only from its objects by opening up its conduits for bogus, unsubstantiated and anonymous donations but also acted to benefit its Chairperson directly. The plea that during the year only 2 lakhs had been added to the imprest account does not take away anything from the severe visitation of denial