Section 10(23C)(iiiad) Shields School – AO Cannot Invoke Section 11(5)

ABM Senior Secondary Public School Society Vs ITO (Exemptions) (ITAT Chandigarh)

Assessee, a registered society, runs a school affiliated to HP Board, imparting education up to 12th standard. Gross receipts during AY 2015-16 did not exceed ₹1 crore. AO noticed assessee had advanced ₹59.50 lakh as rent advance to specified persons & held it in violation of Section 11(5). Addition of ₹59.50 lakh was made by Faceless Assessment Unit. CIT(A) deleted ₹20.64 lakh but sustained ₹38.86 lakh addition.

Tribunal’s Observations

• Assessee’s receipts w

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