Denial of Section 11 Exemption Does Not Permit Taxation of Gross Receipts: ITAT Mumbai

Adhi Ganesh Mandir Charitable Trust Vs Income Tax Department (ITAT Mumbai)

The appeal before the Income Tax Appellate Tribunal (ITAT), Mumbai, arose from the order dated 25.08.2025 passed by the National Faceless Appeal Centre (NFAC), Delhi, relating to assessment year 2023–24. The assessee-trust challenged the denial of exemption under Section 11 of the Income-tax Act, 1961, and the action of the Assessing Officer in taxing the entire receipts of ₹6,94,592/- without allowing deduction of expenditure incurred for charitable activities.

The assessee had filed its return o

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