Bible Fellowship Centre Wagholi Vs ITO (ITAT Pune)
The captioned appeal concerns the Assessment Year (A.Y.) 2016-17 and arises against the order dated 15.07.2025 of Addl/JCIT(A)-3, Chennai, which emanated from the Assessment Order dated 29.11.2018 under Section 143(3) of the Income Tax Act, 1961. The assessee, a charitable trust, raised five grounds of appeal, primarily concerning two issues: (i) denial of deduction under Section 11(1)(a) of the Act at Rs. 4,82,850 for non-submission of Audit Report on Form 10B, and (ii) denial of deemed application of Rs. 8,09,074 under Form 9A as per clause 2 of Explanation 2 to Section 11(1) for non-filing within the prescribed time.
The assessee had filed its return for A.Y. 2016-17 on 29.10.2016. The case was selected for scrutiny through CASS due to “Approval obtained u/s. 80G and large increase in total voluntary contributions.” The Assessing Officer (AO), during scrutiny under Sections 143(2) and 142(1), observed that although Form 9A and Form 10B were purportedly filed online on 29.10.2016, Form 9A was not visible on the e-filing portal, and the Audit Report on Form 10B was not submitted within the due date under Section 139(1). Consequently, the AO denied both claims and assessed the total income at Rs. 12,91,924.
