Rinchen Zangpo Endowment Society Vs ITO (ITAT Delhi)
In the case of Rinchen Zangpo Endowment Society Vs ITO, the appeal arose from an order passed by the Commissioner of Income Tax (Appeals) [CIT(A)] dated 15.01.2026 for Assessment Year 2021–22. The assessee, a registered charitable society, had filed its return of income declaring NIL income after claiming exemption under Sections 11 and 12 of the Income Tax Act, 1961. During the relevant year, the assessee received foreign contributions amounting to ₹10,30,324, which were duly recorded in its books of account and also reflected in the return of income.
However, while filing the return, the assessee inadvertently disclosed the foreign contribution under the wrong schedule. Instead of reporting it in ‘Schedule-VC’, the amount was shown in ‘Schedule-AI’. During processing under Section 143(1), the Central Processing Centre (CPC) identified this discrepancy and treated it as non-disclosure in the appropriate schedule, resulting in an addition of ₹10,30,324 to the income.
The assessee contested the addition before the CIT(A), explaining that the foreign contribution had not been suppressed and was fully disclosed in both the books of account and the return of income, albeit under an incorrect schedule. The CIT(A) acknowledged that the amount was disclosed but upheld the addition solely on the ground that the assessee failed to correct the error by filing a revised return or seeking condonation.
