ROHILKHAND EDUCATIONAL CHARITABLE TRUST,BAREILLY vs. DCIT, CENTRAL CIRCLE, BAREILLY
In the result, both appeals of the assessee in ITA No
ITA 181/LKW/2024[2017-18]Status: DisposedITAT Lucknow22 Sept 2025AY 2017-18
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
For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. S.H. Usmani, CIT DR
Section 11Section 11(1)Section 11(2)Section 12ASection 13(3)Section 143(3)Section 250Section 80GSection 80G(5)
trust. The assessment was completed allowing the exemption under section 11, including accumulation under section 11(2).
Subsequently, the ld. Commissioner revised the case under section 263. According to him, section 11(2) contemplated only specific or concrete purposes and since those were not specified by the assessee, the assessment order was erroneous and prejudicial to the interest of revenue
