Lakshmiammal Progressive Educational Trust Vs ITO (ITAT Chennai)
This summary strictly uses only the information provided in the Full Text of the Order of ITAT Chennai regarding the appeal filed by Lakshmiammal Progressive Educational Trust against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the Assessment Year 2018-19.
Procedural Background and Condonation of Delay
The appeal was filed by the assessee, Lakshmiammal Progressive Educational Trust, which is a public charitable trust registered under section 12AA of the Income Tax Act, 1961 (the Act), and runs an educational institution. The appeal was directed against the NFAC order dated April 23, 2025. There was a delay of 36 days in filing the appeal. The ITAT reviewed the assessee’s petition and affidavit, concluding there was sufficient cause for the belated filing, and therefore condoned the delay to dispose of the appeal on merits.
Facts of the Case and Initial Assessment
For the Assessment Year 2018-19, the assessee filed a return on October 30, 2018, showing a surplus over expenses of Rs. 49,03,218/-, which was claimed as exempt under section 11 of the Act. During assessment proceedings, the Assessing Officer (AO) found that the trust had received a total of Rs. 31,60,400/- in cash donations. As the assessee failed to submit details of these donations before the assessment was completed, the AO, in the order dated January 29, 2021, treated the entire amount of Rs. 31,60,400/- as anonymous donation and taxed it under section 115BBC of the Act.
