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

charitable trust and no tax benefit could accrue on claiming bogus expenditure as the income of the trust was not chargeable to tax on account of the availability of exemption under section 11. Furthermore, in assessment years 2013-14, 2014-15, 2015-16 and 2016-17, no such disallowance had been made. It was further submitted that in the case