SARSWATI VIDHYA PRATISHTHAN M.P ,BHUPAL vs. THE ACIT 2(1), BHOPAL
In the result, appeal of assessee is allowed
ITA 392/IND/2022[2012-13]Status: DisposedITAT Indore30 Aug 2023AY 2012-13
Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisarswati Vidhya Pratishthan Dcit (E) M.P. Bhopal Vs. 01, Harshwardhan Nagar Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aadas0899M Assessee By Shri Santosh Deshmukh & Shri Parth Jhawar, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.08.2023 Date Of Pronouncement 30.08.2023
Section 11Section 11(1)(a)Section 12ASection 143Section 143(3)Section 263
271(1)(c) of the Act are initiated separately.”
5.1
Thus, it is clear that the AO has disallowed the claim primarily on two grounds, that this expenditure is incurred for organizing the Shivir/celebration and not proportionate to the normal expenditure incurred by the assessee on providing education to the students. The second objection of the AO is that this