Reopening for Section 68 but Taxing u/s 115BBC Is Jurisdictional Mismatch: Pune ITAT Quashes Reassessments

Rajarshi Shahu Shikshan Sanstha Vs ITO (Exemption) (ITAT Pune) Reopening for Section 68 but Taxing u/s 115BBC Is Jurisdictional Mismatch: Pune ITAT Quashes Reassessments of Educational Trust Pune ITAT, ‘B’ Bench, in Rajarshi Shahu Shikshan Sanstha Vs ITO (Exemption) (ITA Nos.1121 to 1126/PUN/2024; AYs 2012-13 to 2017-18; order dated 18-12-2025), allowed the assessee-trust’s appeals and quashed the reassessment proceedings u/s 147 on a pure jurisdictional ground, without entering into merits of anonymous donations. The Tribunal noted that the reasons recorded for reopening were exclusivel...