Archana Foundation Vs Asst. Director of Income Tax (ITAT Mumbai)
The Income Tax Appellate Tribunal (ITAT) Mumbai has issued a ruling in favor of Archana Foundation, a registered public charitable trust, allowing its claim for deduction under Section 11(2) of the Income Tax Act, 1961, for the Assessment Year 2019-20. The decision, pronounced on May 6, 2025, overturns a previous order by the Commissioner of Income-tax (Appeal) (CIT(A)) dated January 20, 2025, which had upheld the denial of the exemption by the Central Processing Centre (CPC), Bengaluru, acting as the Assessing Officer (AO). The denial stemmed from an 18-day delay in the foundation’s submission of its return of income and supporting forms.
Archana Foundation, operating under Section 12A of the Income Tax Act, is engaged in social welfare activities, including running an old-age home (‘Matoshree Vriddhashram’) and a school, with a stated focus on the upliftment of the “Adivasi” community. For the Assessment Year 2019-20, the trust filed its income tax return on November 18, 2019. This filing was 18 days beyond the statutory due date of October 31, 2019. Concurrently, the foundation submitted Forms 9A and 10B, as mandated under Rule 17B of the Income Tax Rules, 1962, which are essential for claiming deductions under Section 11(2) of the Act for income accumulated over expenditure.
