ROHILKHAND EDUCATIONAL CHARITABLE TRUST,BAREILLY vs. DCIT, CENTRAL CIRCLE, BAREILLY

In the result, both appeals of the assessee in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.181 & 182/Lkw/2024 A.Ys.2017-18 & 2018-19 Rohilkhand Educational Vs. Dcit, Charitable Trust, Bareilly Central Circle, Bareilly Pan: Aaatr6902J (Appellant) (Respondent) Assesseeby: Sh. Rakesh Garg, Adv Revenue By: Sh. S.H. Usmani, Cit Dr Date Of Hearing: 14.08.2025 Date Of Pronouncement: 22.09.2025 O R D E R Per Bench: [ These Two Appeals Have Been Filed By The Assessee Against The Separate Orders Of The Ld. Cit(A)-3, Lucknow Dated 19.03.2024 & 22.03.2024, Passed Under Section 250 Of The Income Tax Act, 1961, For The A.Ys. 2017-18 & 2018-19, Dismissing The Appeals Of The Assessee Against Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “(1).That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Not Considering The Fact That In The Alleged Assessment Order, The Columns Of Name Of Assessee, Pan, Asst Year, Date Of Assessment & Section Under Which Passed, Are Blank. (2)That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Treating The Demand As Valid Which Was Not Computed On The Basis Of Orderthat May Not Be Termed To Be An Order Under Section 143(3). (3) That A Demand Of Tax As Computed In The Computation Sheet Is Without Jurisdiction Void-Ab-Inito & Is Liable To Be Annulled. (4) That The Ld. Authorities Below Have Erred In Law As Well As On Facts In Confirming The Addition Of Rs. 736591857/-Comprising  Corpus Donation Aggregating To Rs 7,68,95,000/-, A.Ys. 2017-18 & 2018-19

disallowed the benefit of surplus of income which was exempt as per the provisions of section 11, only on account of the fact that there was perceived violation of section 13(1

INCOME TAX OFFICER-2(3), LUCKNOW vs. U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

1 (Del). the ld. CIT(A) held that in the case of the assessee, the purpose of accumulation of setting apart the income to attain the objects showed a lack of application of mind and specificity as prescribed in section 11(2) of the Act. He, therefore, held that if the contention of the assessee were to be accepted

U.P HOUSING & DEVELOPMENT BOARD,LUCKNOW vs. INCOME TAX OFFICER-2(3), LUCKNOW

Accordingly all four additional grounds filed by the revenue in Appeal numbers 532 & 533 of 2014, stand dismissed

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

1 (Del). the ld. CIT(A) held that in the case of the assessee, the purpose of accumulation of setting apart the income to attain the objects showed a lack of application of mind and specificity as prescribed in section 11(2) of the Act. He, therefore, held that if the contention of the assessee were to be accepted

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

1 (Del). the ld. CIT(A) held that in the case of the assessee, the purpose of accumulation of setting apart the income to attain the objects showed a lack of application of mind and specificity as prescribed in section 11(2) of the Act. He, therefore, held that if the contention of the assessee were to be accepted

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

1 (Del). the ld. CIT(A) held that in the case of the assessee, the purpose of accumulation of setting apart the income to attain the objects showed a lack of application of mind and specificity as prescribed in section 11(2) of the Act. He, therefore, held that if the contention of the assessee were to be accepted

INCOME TAX OFFICER-2(3), LUCKNOW vs. U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

1 (Del). the ld. CIT(A) held that in the case of the assessee, the purpose of accumulation of setting apart the income to attain the objects showed a lack of application of mind and specificity as prescribed in section 11(2) of the Act. He, therefore, held that if the contention of the assessee were to be accepted

U.P HOUSING & DEVELOPMENT BOARD,LUCKNOW vs. INCOME TAX OFFICER-2(3), LUCKNOW

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

1 (Del). the ld. CIT(A) held that in the case of the assessee, the purpose of accumulation of setting apart the income to attain the objects showed a lack of 19 ITA Nos.532 & 533/LKW/2014 ITA Nos.534 & 535/LKW/2014 ITA Nos.21 & 22/LKW/2019 U.P. Awas Evam Vikas Parishad application of mind and specificity as prescribed in section 11

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

1)(d) and 13(3) of the Act. Revenue also submitted grounds on 19.03.2021 as an abundant caution again pointing out the non-consideration of Sections 11(2) and 11(3) and also the specific items of disallowance

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

1)(d) and 13(3) of the Act. Revenue also submitted grounds on 19.03.2021 as an abundant caution again pointing out the non-consideration of Sections 11(2) and 11(3) and also the specific items of disallowance

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

1)(d) and 13(3) of the Act. Revenue also submitted grounds on 19.03.2021 as an abundant caution again pointing out the non-consideration of Sections 11(2) and 11(3) and also the specific items of disallowance

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

1)(d) and 13(3) of the Act. Revenue also submitted grounds on 19.03.2021 as an abundant caution again pointing out the non-consideration of Sections 11(2) and 11(3) and also the specific items of disallowance

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

1)(d) and 13(3) of the Act. Revenue also submitted grounds on 19.03.2021 as an abundant caution again pointing out the non-consideration of Sections 11(2) and 11(3) and also the specific items of disallowance

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

1)(d) and 13(3) of the Act. Revenue also submitted grounds on 19.03.2021 as an abundant caution again pointing out the non-consideration of Sections 11(2) and 11(3) and also the specific items of disallowance

ASTT. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

1)(d) and 13(3) of the Act. Revenue also submitted grounds on 19.03.2021 as an abundant caution again pointing out the non-consideration of Sections 11(2) and 11(3) and also the specific items of disallowance

ASTT. COMMISIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

Bench: Shri A. D. Jain & Shri T. S. Kapoor

1)(d) and 13(3) of the Act. Revenue also submitted grounds on 19.03.2021 as an abundant caution again pointing out the non-consideration of Sections 11(2) and 11(3) and also the specific items of disallowance

MORADABAD DEVELOPMENT AUTHORITY,MORADABAD vs. DY. CIT(EXEMPTION), LUCKNOW

In the result, ITA No. 1071/Del/2020, ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

1. The Ld. CIT (Appeals) has erred in law and against the facts for recalling his earlier order by invoking the provisions of section 154 of the LT. Act. 2. That the Ld. CIT (Appeals) has erred both in law and on facts for disallowing the exemption u's 11

DY. CIT(EXEMPTION), LUCKNOW vs. MORADABAD DEVELOPMENT AUTHORITY, MORADABAD

In the result, ITA No. 1071/Del/2020, ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

1. The Ld. CIT (Appeals) has erred in law and against the facts for recalling his earlier order by invoking the provisions of section 154 of the LT. Act. 2. That the Ld. CIT (Appeals) has erred both in law and on facts for disallowing the exemption u's 11

MORADABAD DEVELOPMENT AUTHORITY,MORADABAD vs. DCIT(EXEMPTION), LUCKNOW

In the result, ITA No. 1071/Del/2020, ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

1. The Ld. CIT (Appeals) has erred in law and against the facts for recalling his earlier order by invoking the provisions of section 154 of the LT. Act. 2. That the Ld. CIT (Appeals) has erred both in law and on facts for disallowing the exemption u's 11

MORADABAD DEVELOPMENT AUTHORITY,MORADABAD vs. DCIT(EXEMPTION), LUCKNOW

In the result, ITA No. 1071/Del/2020, ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

1. The Ld. CIT (Appeals) has erred in law and against the facts for recalling his earlier order by invoking the provisions of section 154 of the LT. Act. 2. That the Ld. CIT (Appeals) has erred both in law and on facts for disallowing the exemption u's 11