Case Law Details
Samaja Seva Mandali Vs ITO (ITAT Bangalore)
The case of Samaja Seva Mandali versus ITO (Income Tax Officer) heard before the Income Tax Appellate Tribunal (ITAT) Bangalore involved cross appeals by both the assessee and the revenue regarding different orders passed by the National Faceless Assessment Centre (NFAC) for the assessment year 2018-19 under the Income Tax Act, 1961.
In the appeal filed by the assessee (ITA No.33/Bang/2024), the main issue revolved around quantum additions made by the assessing officer. The assessee, a charitable trust engaged in providing education, had filed a return of income declaring NIL income, claiming exemption under section 11(1) of the Act. However, the assessing officer, after scrutiny, disallowed certain expenses incurred by the assessee, leading to a determination of taxable income. The NFAC upheld the assessing officer’s decision, prompting the assessee to file an appeal before the ITAT.
The grounds of appeal raised by the assessee covered various aspects, including challenging the denial of exemption for amounts applied towards the purchase of land, disputing the assessing officer’s findings, and contesting the imposition of interest under sections 234A, 234B, and 234C of the Act.
The crux of the assessee’s argument was that the amounts expended for purchasing land were applied out of exempt income and should therefore qualify for exemption under section 11(1) of the Act. The assessee provided details of the agreements to sell entered into for the purchase of land, along with payment receipts and other relevant documents, to substantiate its claim.
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