THE JANSEVA TRUST,GODHRA vs. THE INCOME TAX OFFICER, WARD 4(1)(2), VADODARA (NOW INCOME TAX OFFICER, WARD 1, GODHRA), GODHRA
In the result, the appeal of the assessee is allowed for statistical purposes, subject to the above directions
ITA 851/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2025AY 2017-18
Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.851/Ahd/2023 िनधा"रण वष" /Assessment Year : 2017-18 The Janseva Trust The Ito बनाम/ Opp. Gyandeep School Ward-4(1)(1)(2), Vadodara V/S. Nr.Jivanlal Hospital (Now Ito, Ward-1, Godhra – 389 001 (Gujarat) Godhra – 389 001) "थायी लेखा सं./Pan: Aaatt 2888 D (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Ms. Nikhita Bhamblani & Amrin Pathan, Ars Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 27/01/2025 घोषणा की तारीख /Date Of Pronouncement: 29/01/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], Dated 29.08.2023, For The Assessment Year (A.Y.) 2017-18. The Said Appeal Arises From The Assessment Order Passed By The Income Tax Officer (Ito), Ward 4(1)(2), Vadodara [Hereinafter Referred To As “Ao”], Under Section 144 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act)”], On 24.12.2019. The Janseva Trust Vs. Ito Asst. Year : 2017-18
For Appellant: Ms. Nikhita Bhamblani &For Respondent: Shri Rignesh Das, Sr.DR
Section 115BSection 139(1)Section 142(1)Section 144Section 69A
charitable micro-finance activities. However, no reconciliation of these deposits with individual borrower accounts or adequate supporting evidence was provided at any stage of the proceedings.
The AO invoked Section 69A of the Act to treat the deposits as unexplained income. While the assessee's explanation of loan recoveries was not properly verified by the AO, the onus