Income Tax Appellate Tribunal - Chennai
Ceoa Educational Society,Madurai vs Acit Exemptions, Coimbatore on 15 April, 2026
आयकर अपीलीय अिधकरण 'सी' ायपीठ, चे ई।
IN THE INCOME TAX APPELLATE TRIBUNAL
'C' BENCH: CHENNAI
माननीयासु ी प ावतीएस, ले खासद ा एवं
माननीय ीमनु कुमार िग#र , ाियक सद के सम%
BEFORE MS. PADMAVATHY S, ACCOUNTANT MEMBER AND
SHRI MANU KUMAR GIRI, JUDICIAL MEMBER
आयकरअपीलसं./ITA No.2985/Chny/2025
नधारणवष/Assessment Year: 2018-19
CEOA EDUCATIONAL SOCIETY v. ACIT EXEMPTIONS
64/2,Sriram Nagar, Kalainagar Extn, May Flower Mid City Building,
A.Kosakulam, Madurai, Madurai ACIT EXEMPTIONS, COIMBATORE,
Tamil Nadu-625017 Coimbatore, Tamil Nadu- 641018
[PAN: AAATC5832C]
(अपीलाथ /Appellant) ( यथ /Respondent)
अपीलाथ' की ओर से/ Appellant by : Mr. R. Viswanathan, C.A.
)*थ' की ओर से /Respondent by : Ms. R. Anitha, Addl. C.I.T.
सुनवाईक तार ख/Date of Hearing : 26.02.2026
घोषणाक तार ख /Date of Pronouncement : 15.04.2026
आदे श / O R D E R
PER MANU KUMAR GIRI, JM:
This appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2018-19 dated 29.08.2025.
2. Facts of the case are as under:
The appellant submitted its return of income on 26.10.2018 within the prescribed due date, declaring a total income of Nil, as it had obtained approval for exemption under Section 10(23C).ITA No.2985/Chny/2025 (AY: 2018-19)
CEOA Education Society Vs ACIT :- 2 -:
However, due to an inadvertent error in the auditor's office, Form 10B was filed on 26.10.2018 (Acknowledgment No. 348247361261018), under the mistaken belief that it was the correct form. Upon receipt of the notice, this mistake was identified. Immediately thereafter, the auditor rectified the error by filing the revised return in Form 10BB on 04.07.2020 (Acknowledgment No. 380701291040720). This correction was made within 612 days from the due date.
Subsequently, the appellant filed a petition on 15.09.2020 seeking condonation of delay in filing Form 10BB. However, the Commissioner of Income Tax (Exemptions), Chennai rejected the request on the ground that the delay exceeded the authority vested in the office. In accordance with Circular No. 15/2022 dated 19.07.2022 issued by the Central Board of Direct Taxes (CBDT), the appellant has filed a petition before the Principal Commissioner of Income Tax (Exemptions) seeking condonation of the delay. The appellant is currently awaiting decision thereon.
3. On appeal by the assessee, the ld. CIT(A) upheld the action of the AO by observing that in this case, the demand has been raised in the computation due to non-filing of Form 10BB. According to the appellant, the matter relating to condonation of delay is ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 3 -:
pending before the Principal Commissioner of Income Tax (Exemptions) and therefore falls outside the scope of the present appeal. Accordingly, the appeal is treated as infructuous and is dismissed for statistical purposes. In the result, the appeal is dismissed.
4. On further appeal before this Tribunal, the ld.AR contended that due to an inadvertent error in the auditor's office, Form 10B was filed on 26.10.2018 (Acknowledgment No. 348247361261018), under the mistaken belief that it was the correct form. Upon receipt of the notice, this mistake was identified. Immediately thereafter, the auditor rectified the error by filing the revised return in Form 10BB on 04.07.2020 (Acknowledgment No. 380701291040720). He also relied upon the order of the Pune Bench of Tribunal in the case of ACIT vs. Nanded SikhgurudwaraSachkhandHazur Sahib [2025] 174 taxmann.com 1116 (Pune - Trib.)[26-05-2025] which held as under:
7.2.1. The case of the present assessee has been decided by the Hon'ble ITAT Pune in its judgment delivered in ACIT v. Nanded SikhgurudwaraSachkhandHazurApchalnagar Sahib [2022] 141 taxmann.com 427 (Pune Trib.) for AY 2014-15 where the facts and circumstances of the case are exactly similar. The judgment of the Hon'ble ITAT is reproduced here as under-
"2. The Revenue raised the following grounds of appeal:-
1. The Ld. CIT(A), has erred in allowing exemption u/s 10(23C)(v) of the Act in the given facts of the case, particularly the assessee failed to furnish Audit report in Form No. 10BB us 10(23C) (v) r.w.r. 16CC AX DEPAR ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 4 -:
2. The Ld. CIT(A), has erred in granting exemption u/s 11 of the Act by accepting Form No. 10 filed during the course of assessment proceedings, even though the Trust is not registered u/s 12A of the Act."
3. Briefly, the facts of the case are that the respondent-assessee is a religious and charitable trust engaged in the work of managing the administration and functioning of Sikh Gurdwara Sachkhand Shri Hazur Sahib, Nanded. It is to be noted that "The Nanded Sikh Gurudwara SachkhandHazurApchchalnagar Sahib" as anonymous body constituted by the Govemment under the Nanded Sikh Gurudwara SachkhandHazurApchchalnagar Sahib Act, 1956 by way of notification in the official Gazette of the Hyderabad Government vide Gazette Extraordinary No. 216. It is registered under the Charitable and Religious Trusts Act, 1920 (Central Act XIV of 1920) and the Bombay Public Trusts Act, 1950. The respondent-assessee filed the return of income for the assessment year 2014-15 declaring Rs. Nil income after claiming exemption of income under the provisions of section 10(230)(v) of the Income-tax Act, 1961 (the Act) Against the said return of income, the assessment was completed by the Assistant Commissioner of Income Tax. Exemption Circle Aurangabad (the Assessing Officer) vide order dated 30-12-2016 passed us 143(3) of the Act of total income of Rs. 24,33,51,386/- denying the claim for exemption of Income u/s 10(23C) (v) on the ground that the respondent-assessee trust generated surplus of 41% of the gross receipts indicating that the funds were not utilized for which the trust was formed. Secondly, the respondent-assessee trust does not enjoy the registration u/s 12AA of the Act. Also the fact that Form No. 10 was not filed within the due date.
4. Being aggrieved by the above assessment of order, an appeal was preferred before the Ld. CIT(A) contending that the submission of audit report before the competent authorities constitutes sufficient compliance and, therefore, there is no requirement under the law that in order to avail the exemption u/s 10(23C)(v) of the Act. The Trust should also enjoy the registration u/s 12AA of the Act and finally the mere fact that the respondent-assessee generated surplus does not lead to conclusion that the funds were not properly utilized by the respondent-assessee trust. The ld. CIT(A) considering the following decisions relied upon by the respondent-assessee Hon'ble Supreme Court in the case of (i) CIT v. Nagpur Hotel Owner's Association (2001) 114 Taxman 255/247 ITR 201 , (ii) Hon'ble Gujarat High Court in the case of ACIT v Stock Exchange Ahmedabad (2012) 25 taxmann.com 469/210 Taxman 28 and (iii) Hon'ble Delhi High Court in the case of Association of Corporation & Apex Societies of Handlooms v. Asstt. DIT (2013) 30 taxmann.com 22/213 Taxman 15/351 ITR 287 held that furnishing of audit report before completion of the assessment proceedings would constitute sufficient compliance and claim for exemption u/s 10(23C)(v) cannot be denied. Similarly, the ld. CIT(A) also held that the findings of the Assessing Officer that the funds of the trust were not properly utilized is bald allegation as the respondent-assessee trust is supervised by the District Collector The office of the Charity Commissioner also not found any irregularity in the functioning of the trust as well as funds utilized by the respondent-assessee trust. Accordingly, the ld. CIT(A) directed the Assessing Officer to grant the exemption u/s 10(23C)(v) and delete the addition of Rs.24,33,51,366/-.
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5. Being aggrieved by the above decision of the Id. CIT(A), the Revenue is in appeal before us in the present appeal.
6. The ld CIT-DR submits that mere fact that the respondent-assessee trust had generated surplus of 41% goes to prove that the funds were not properly utilized by the respondent-assessee trust. He further submitted that the ld. CIT(A) ought not to have held that the filling of the audit report before completion of the assessment proceedings constitutes a sufficient compliance under the provisions of the Act, as it is contrary to the plain provisions of the Act which stipulates under second proviso and third proviso of section 10(23C)(v) of the Act the audit report should be filed within due date of filing return of income u/s 139 of the Act. He further contended that the Id. CIT(A) ought not to have held that the findings of the Assessing Officer that the funds were not properly utilized, administered and supervised is bald in the absence of any material on record controverting the findings of the Assessing Officer He further submitted that the respondent-assessee trust was granted registration u/s 12AA only on 15-5-2017 which is applicable from financial year 2016-17 onwards Thus, in the absence of any registration u/s 12AA, the respondent-assessee trust is not entitled for benefit of exemption under the provisions of section 10(23C)(v) of the Act.
7. On the other hand, ld. AR for the respondent-assessee trust submitted that the observation of the ld. CIT(A) that the finding of the Assessing Officer that the funds of trust were not properly utilized and the affairs of the trust were not properly managed is bald, is correct, inasmuch as, the affairs of the trust were managed under the direction and control of the District Collector. He further submitted that the fact that audit report in the prescribed form was not submitted by the respondent-assessee trust within the due date for filing the return of income cannot come in the way of granting exemption u/s 10(230)(v), inasmuch as, the requirement of filing the audit report in the prescribed form is only directory and it would be sufficient compliance if audit report is submitted before completion of the assessment proceedings. He further submitted that mere generation of surplus does not lead to conclusion that the trust is not existing only public religious and charitable purposes.
As regards to the registration u/s 12AA, he submitted that there is no requirement under the provisions of section 10(23C)(v) that the claim for exemption under this section can be allowed only if the registration u/s 12AA is granted.
8. We heard the rival submissions and perused the material on record. The issue in the present appeal relates to the exemption under the provisions of section 10(23C)(v) of the Act. Admittedly, the respondent- assessee trust was granted approval u/s 10(23C)(v) of the Act. However, the Assessing Officer had denied the claim for exemption u/s 10(23C)(v) primarily on the ground that:
(i) The funds of the trust were not properly utilized/supervised.
(ii)The respondent-assessee trust does no enjoy the registration under the provisions of section 12AA of the Act.ITA No.2985/Chny/2025 (AY: 2018-19)
CEOA Education Society Vs ACIT :- 6 -:
(iii)The audit report in the prescribed form was not filed within the stipulated date i.e. along with return of income filed u/s 139(1) of the Act.
9. On appeal before the ld. CIT(A), the ld. CIT(A) was of the opinion that the Assessing Officer was not justified in observing that the funds of the trust were not property utilized without bringing any material on record.
Further, as regards to the filing of audit report in the prescribed form, the Ld. CIT(A) placing reliance on the decision of the Hon'ble Supreme Court in the case of Nagpur Hotel Owner's Association (supra) held that if the audit report was filed before the completion of the assessment proceedings, it would meet the requirement of law as the provision of Act is a directory in nature. Thus, the appeal of the respondent-assessee trust was allowed by the ld. CIT(A).
10. We find from maternal on record that the observation made by the Assessing Officer that the funds of the trust were not properly utilized, managed and supervised is mere bald observation as there was no material brought on record in support of the above allegation, Further, we find that the funds of the trust are managed by the member of the trustees headed by the District Collector, no mala fide can be attributable to Government authorities in the absence of any evidence. The Assessing Officer holding the position of quasi judicial authority, should refrain from making bald allegation without bringing on record conclusive evidence in support of such allegation From reading of the assessment order, it appears that the Assessing Officer is carried away by the fact that the respondent-assessee trust generated surplus of funds of 41% of gross receipts and inferred that the funds were not utilized for the object for which the respondent-assessee trust was formed. The Hon'ble Supreme Court in the case of Queen's Educational Society v CIT [2015] 55 taxmann.com 255/231 Taxman 286/372 ITR 699 held that merely because a charitable trust had generated surplus does not lead to conclusion that the appellant trust is not charitable or religious exiting for the purpose of profit. To the similar effect in the decision of the Hon'ble Supreme Court in the case of Aditanar Educational Institution v. Addl. CIT [1997] 90 Taxman 528/224 ITR
310. Therefore, the Assessing Officer cannot jump to the conclusion that the respondent-assessee trust is not religious and charitable trust merely because it generated surplus income.
11. We have carefully gone through the provisions of section 10(23C)(v) which does not prescribe any stipulation, which makes the registration u/s 12AA as a condition precedent for availing the exemption u/s 10(23C)(v) of the Act. In fact, the provisions of section 11 and section 10/23C)(v) are two parallel regimes and operate independently in their respective realms. This position was clarified by CBDT Circular No.14 of 2015 dated 17-8-2015. Further, it is well-known canon of construction of the Statute, no words can be added to in Act or a new stipulation which is not prescribed in the statute can be read into the Act as held by the Hon'ble Supreme Court in the case of CIT v. VadilalLallubhai [1972] 86 ITR 2.
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As regards to the delay in filing the audit report in the prescribed form, the Courts have taken a consistent view that filing of audit report in the prescribed form before completion of the assessment proceedings would constitute a sufficient compliance under the provisions of the Act as held by the Hon'ble Supreme Court in the case of Nagpur Hotel Owner's Association (supra), also by the Hon'ble Punjab & Haryana High Court in the case of National Horticulture Board v. Chief CIT (2009) 176 Taxman 167/319 ITR 74 and the Hon'ble Delhi High Court in the case of Association of Corporation & Apex Societies of Handlooms (supra). Even the CBDT Circular No. 19 of 2020 w.e.f. 3-11-2020 as amended by the CBDT Circular No 6 of 2021 dated 26-3-2021 had authorized the Commissioner of Income-tax to entertain the application belatedly up to the assessment year 2018-19. Thus, in the light of the above discussions, we do not find any illegality and unreasonableness in the order of the Id CIT(A) in reversing the findings of the Assessing Officer denying the exemption u/s 10(23C)(v) of the Act. In view of findings given by us supra, none of reasons assigned by Assessing Officer, while denying the claim of exemption u/s 10(23C)(v) can be sustained in the eyes of law. We do not find any merits in the grounds of appeal filed by the Revenue. Accordingly, the grounds of appeal filed by the Revenue stand dismissed.
12. In the result, the appeal filed by the Revenue stands dismissed."
7.2.2. As seen above, the Hon'ble ITAT Pune has held that there was no material brought on record by the AO in support of his observation that the funds of the trust were not properly utilized, managed and supervised and held the observation of the AO as a bald observation. It further held that filing of audit report in the prescribed form before completion of the assessment proceedings is sufficient compliance under the provisions of the Act 7.2.3. In view of the above facts and respectfully following the judgment of Hon'ble ITAT Pune (supra) and further in view of CBDT Circular 19/2020, addition of Rs. 28,02.93,045/- on the ground of late filing of Form 10BB is hereby deleted. Accordingly, Grounds of appeal are allowed.
8. In the result, the appeal is allowed. Order passed under section 250 read with section 251 of the Act."
6. Aggrieved with such order of the Ld. CIT(A) / NFAC, the Revenue is in appeal before the Tribunal by raising the following grounds:
1.On the facts and circumstances of the case and in law the Ld. CIT(A) has erred in allowing the appeal of the assessee by accepting the plea of the assessee that filing of statutory forms in Form 10/10B can be made acceptable during assessment proceedings subsuming the error of the assessee ipso facto the decision of Hon'ble Supreme Court in the case of CIT v. Nagpur Hotel owner's Association [2001] 114 Taxman 255/247 ITR 201 (SC)/114 Taxmann 255 without discussing the element of bonafide belief or meeting of purposes of timely filing of the statutory forms and without interpreting the statute on the basis of ratio laid vide the Apex Court for strict interpretation of statute in the case of exemption regime in ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 8 -:
Commissioner of Customs (Imports), Mumbai v. Dilip Kumar & Company &Ors. in Commissioner of Customs (Import), Mumbai v. Dilip Kumar [2016] 69 taxmann.com 206(SC) /Commissioner of Customs (Import), Mumbai v.
Dilip Kumar [2016] 69 taxmann.com 206(SC) /Commissioner of Customs (Import), Mumbai v. Dilip Kumar [2016] 69 taxmann.com 206(SC) /Civil Appeal No 3327 of 2007 and The Principal Commissioner Of Income v. M/S Wipro Limited in Pr. CIT v. Wipro Ltd. [2022] 140 taxmann.com 223/288 Taxman 491/446 ITR 1 (SC)/Pr. CIT v. Wipro Ltd. [2022] 140 taxmann.com 223/288 Taxman 491/446 ITR 1 (SC)/CIVIL APPEAL NO. 1449 OF 2022
2.On the facts and circumstance of the case, Ld. CIT(A) erred in allowing the alternate plea of the assessee without considering the decision of Hon'ble High Court of Bombay in the case of Little Angels Education Society v. Union of India and others in WRIT PETITION NO 1061 OF 2020 wherein the Hon'ble court has denied any relief to the assessee as regards the plea to condone the delay and deeming it appropriate to revert the matter to be competent authorities
3.On the facts and circumstance of the case, Ld CIT(A) erred in allowing the plea of the assessee without considering the decision of Hon'ble Apex court in M/s. Vishwanath Traders v. Union of India &Ors. [Special Leave to Appeal (C) No(s) 15594 of 2023 dated August 04, 2023] wherein the Apex Court has upheld the requirements of exercising all possible alternative remedies.
7. The Ld. DR strongly opposed the order of the Ld. CIT(A) / NFAC. He submitted that the Pune Bench of Tribunal while deciding the issue for assessment year 2014-15 has followed the decision of the Hon'ble Supreme Court in the case of CIT v. Nagpur Hotel Owner's Association [2001] 114 Taxman 255 / 247 ITR 201 (SC) where it has been held that it is sufficient for the assessee to submit before the assessing authority the required form 10B during the assessment proceedings. However, the Hon'ble Supreme Court in the case Commissioner of Customs (Import), Mumbai v. Dilip Kumar [2016] 69 taxmann.com 206(SC) /Commissioner of Customs (Import), Mumbai v. Dilip Kumar [2016] 69 taxmann.com 206(SC) /Commissioner of Customs (Import), Mumbai v. Dilip Kumar [2016] 69 taxmann.com 206(SC) /Civil Appeal No 3327 of 2007 has held that the exemption provisions are to be visited with strict interpretation of the statute.
8. Referring to the decision of the Hon'ble Supreme Court in the case of Pr. CIT v. Wipro Limited [2022] 140 taxmann.com 223 (SC)/[2022] 288 Taxman 491 (SC)/[2022] 446 ITR 1 (SC /in Civil appeal No.1449 of 2022, he drew the attention of the Bench to the following observations of the Hon'ble Supreme Court:
"14. In view of the above discussion and for the reasons stated above, we are of the opinion that the High Court has committed a grave error in observing and holding that the requirement of furnishing a declaration under Section 10B (8) of the IT Act is mandatory, but the time limit within which the declaration is to be filed is not mandatory but is directory. The same is erroneous and contrary to the unambiguous language contained in Section 10B (8) of the IT Act. We hold that for claiming the benefit under Section 10B (8) of the IT Act, the twin conditions of furnishing a declaration before the assessing officer and that too before the due date of filing the original return of income under section 139(1) are to be satisfied and both are mandatorily to be complied with. Accordingly, the question of law is answered in favour of the Revenue and against the assessee."
9. He also relied on the following decisions:
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(i)Little Angels Education Society v. Union of India [2021] 127 taxmann.com 473 (Bombay)/[2021] 280 Taxman 4 (Bombay)/[2021] 434 ITR 423 (Bombay) / in Writ Petition No.1061 of 2020, order dated 25.03.2021
(ii)Viswanath Traders v. Union of India [2023] 153 taxmann.com 427 (SC )/ vide Special Leave to Appeal (C) No.15594 of 2023, order dated 04.08.2023
(iii)Basawaraj. v. Spl. Land Acquisition Officer [Civil Appeal No.6974 of 2023, dated 22-08-2013].
(iv)Pradeep Kumar Batra v. Dy. CIT [ ITAppeal No. 6384/Del/2019, dated 23.10.2020]
10. He accordingly submitted that the order of the Ld. CIT(A) / NFAC being not in accordance with law should be reversed.
11. The Ld. Counsel for the assessee on the other hand while strongly supporting the order of the Ld. CIT(A) / NFAC submitted that the issue raised by the Revenue in its appeal is directly covered by the decision of the Coordinate Bench of the Tribunal in assessee's own case wherein it has been held that the exemption u/s 10(23C) of the Act is allowable even though the audit report was belatedly filed. He submitted that the audit report in Form 10BB was filed and available with the Assessing Officer during the assessment proceedings.
12. Referring to the decision of the Hon'ble Gujarat High Court in the case of CIT (Exemptions) v. Laxmanarayan Dev ShrishanSevaKhendra [2024] 167 taxmann.com 548 (Gujarat), he submitted that the Hon'ble High Court, after considering the decision of the Hon'ble Supreme Court in the case of PCIT v. Wipro Limited (supra) has held that where assessee, a public charitable trust, did not upload audit report in Form 10B along with its return of income and CPC processed return under section 143(1) denying benefit of section 11, since assessee had already filed audit report in Form 10B electronically during pendency of appellate proceedings along with copy of audited financial statements, delay in filing said form was to be condoned.
13. Referring to the decision of the Hon'ble Gujarat High Court in the case of CIT (Exemption) v. Anjana Foundation [2024] 168 taxmann.com 462 (Gujarat), he submitted that the Hon'ble High Court in the said decision has held that charitable trust cannot be denied benefit of section 11 solely for not filing audit report in Form No.10B, as it is only a procedural requirement.
14. Referring to the decision of the Delhi SMC Bench of the Tribunal in the case of B.R. Hospital Research Institute v. ITO [2024] 167 taxmann.com 389 (Delhi - Trib.), he submitted that the Tribunal, relying on various decisions, has held that conditions of filing Form 10B for availing benefit under section 11 are directory in nature and not mandatory; therefore, where assessee had not filed audit report in Form 10B along with return of income, however filed the same later on before Commissioner (Appeals), claim of assessee for exemption under section 11 was to be allowed.
15. So far as the decision in the case of Viswanath Traders (supra) relied on by Ld. DR is concerned, he submitted that the case was relating to Bihar Goods & Services Tax Act, 2017. Further, the Hon'ble Supreme Court has dismissed the SLP filed. Therefore, the same is not applicable.
16. So far as the decision of the Hon'ble Bombay High Court in the case of Little Angels Education Society (supra) is concerned, he submitted that in that case ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 10 -:
the delay for assessment year 2017-18 was condoned by the CIT(E). So far as assessment year 2018-19 is concerned, the CIT(E) refused to condone the delay which was more than 365 delays. The Hon'ble High Court directed the assessee to approach the CBDT. He submitted that as per CBDT Circular No.5, dated 03.01.2020 the CIT can condone the delay in filing Form 10B when the delay is up to 365 days for assessment year 2018-19 and onwards. He accordingly submitted that the above decision is also distinguishable and not applicable to the facts of the present case.
17. Referring to the decision of the Coordinate Bench of the Tribunal in assessee's own case, he submitted that the Tribunal in the said decision has held that where funds of assessee-charitable trust were managed by member of trustees headed by District Collector and audit report was submitted before competent authorities before completion of assessment proceedings, since there was sufficient compliance to claim exemption under section 10(23C)(v), claim could not be denied merely on the ground that assessee generated surplus income. He accordingly submitted that the order of the Ld. CIT(A) / NFAC being in accordance with law should be upheld and the grounds raised by the Revenue be dismissed.
18. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) / NFAC and the paper book filed by both sides. We have also considered the various decisions cited before us. We find the Assessing Officer in the instant case disallowed the claim of exemption u/s 10(23C) of the Act on the ground that the assessee trust has not filed Form No.10BB before the statutory time limit but has filed the return of income as well as Form No.10BB after the due date of time. Further, the application for condonation of delay filed with the CIT(Exemption) was also rejected by the CIT(Exemption). The Assessing Officer further held that the funds of the trust are not being properly utilized / supervised as required by the provisions of section 10(23C) of the Act. We find the Ld. CIT(A) / NFAC allowed the claim of exemption u/s 10(23C) made by the assessee, the reasons of which have already been reproduced in the preceding paragraphs. We do not find any infirmity in the order of the Ld. CIT(A) / NFAC on this issue.
19. So far as the observations of the Assessing Officer that the funds of the assessee trust are not properly utilized, managed and supervised as required under the provisions of section 10(23C)(v) of the Act is concerned, we find the Ld. CIT(A) / NFAC following the decision of the Coordinate Bench of the Tribunal in assessee's own case has given a finding that the observation of the Assessing Officer is a bald observation. We find the Revenue is not in appeal on this issue as per the grounds of appeal and therefore, we are not concerned with the same.
20. So far as the grievance of the Revenue that the Ld. CIT(A) / NFAC has erred in allowing the appeal of the assessee by holding that filing of audit report in the prescribed form before completion of the assessment proceedings is sufficient compliance under the provisions of the Act is concerned, we find the Ld. CIT(A) / NFAC while deciding the issue has followed the decision of the Coordinate Bench of the Tribunal in assessee's own case for assessment year 2014-15. We find the Hon'ble Gujarat High Court in the case of Laxmanarayan Dev ShrishanSevaKhendra (supra), while deciding an identical issue after considering the decision of the Hon'ble Supreme Court in the case of Wipro Limited (supra), has held that when the assessee has already filed the audit report in Form 10B ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 11 -:
electronically during the pendency of appellate proceedings along with copy of audited financial statements, delay in filing of the said Form is rightly condoned by the Commissioner of Appeals and the Tribunal. The relevant observations of the Hon'ble High Court read as under:
"4. Learned Senior Standing Counsel Ms.Maithili Mehta for the appellant submitted that in case of Principal Commissioner of Income Tax-III, Bangalore v. M/s.Wipro Limited of the Hon'ble Supreme Court rendered on 11th July, 2022 in Civil Appeal No.1449 of 2022 it was held that requirement of Section 10B(8) of the Act which provides for requirement of furnishing declaration for claiming exemption under Section 10B of the Act is mandatory but the time limit within which such declaration is to be filed is also held to be mandatory. Relying upon the aforesaid decision, it was submitted that the assessee ought to have filed the audit report in Form 10B of the Act before the due date of filing of the return to claim the exemption under Section 12A of the Act.
5. Reliance placed by the learned Senior Standing Counsel Ms.Maithili Mehta for the appellant on the decision of the Hon'ble Supreme Court in case of The Principal Commissioner of Income Tax-III and Others versus M/s. Wipro Limited in Civil Appeal No.1499 of 2022 would not be applicable in the facts of the case, as in the facts of the present case, the assessee has claimed the exemption under Section 11 read with Section 12A(1)(b) of the Act which required the assessee to file Audit Report in Form of 10B of the Act which has nothing to do with claiming 100% exemption of total income in respect of newly established 100% Export Oriented Undertakings under Section 10B of the Act. Section 10B(8) of the Act requires the assessee to file an undertaking before the due date of furnishing of return of income under sub- section (1) of Section 139 of the Act before the Assessing Officer in writing that the provision of Section 10B of the Act may not be made applicable to him, otherwise the provision of this Section shall not apply to him for any of the relevant assessment year.
6. Considering the language of the provision of Section 10B(8) of the Act, the Hon'ble Supreme Court held that it was mandatory on part of the assessee to file declaration before the due date of filing of return under Sub- section (1) of Section 139 of the Act, whereas, in the facts of the said case the assessee filed such undertaking along with the revised return under Sub-section (5) of Section 139 of the Act and in such facts, the Hon'ble Supreme Court held that the twin conditions prescribed under Section 10B(8) of the Act was mandatory to be fulfilled and it cannot be said that though the declaration is mandatory, the filing of such declaration within the due date of filing of return under Sub-section (1) of Section 139 of the Act would be directory.
7. Reference to the aforesaid decision has no connection whatsoever remotely to the facts of the present case and therefore, in the facts of the present case, the Tribunal has rightly followed the decision of this Court in case of Sarvodaya Charitable Trust v. Income Tax Officer (Exemption) in Special Civil Application No.6097 of 2020 decided on 09th December, 2020 as well as the decision in case of Social Security Scheme of GICEA (supra) to uphold the decision of the CIT (Appeals), wherein this Court has held that the approach of the authority in such type of cases should be equitable, balancing and judicious. In the facts of the case, when the assessee has already filed the audit report in Form 10B electronically on 27.02.2021 during pendency of appellate proceedings along with copy of audited ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 12 -:
financial statements, delay in filing the said form is rightly condoned by CIT(A) and the Tribunal.
8. In such circumstances, we are of the opinion that the Tribunal has not committed any error by not following the decision in case of M/s.Wipro Limited (supra) as referred to and relied upon by learned advocate for the appellantRevenue, and has rightly followed the decision of this Court in case of Social Security Scheme of GICEA (supra).
9. In view of the foregoing reasons, we are of the opinion that no question of law much less any substantial question of law arises from the impugned order of the Tribunal. The Appeal is accordingly dismissed."
21. We find the Hon'ble Gujarat High Court in the case of Anjana Foundation (supra) has held that a charitable trust cannot be denied benefit of section 11 solely for not filing audit report in Form No.10B, as it is only a procedural requirement.
22. So far as the decision of the Hon'ble Supreme Court in the case of Dilip Kumar & Company. (supra) is concerned, we are of considered opinion that the said decision is not applicable to the facts of the present case as that case was under the Customs Act and not under the Income Tax Act. Further, the facts in that case were that the respondents imported a consignment of Vitamin - F50 powder (feed grade) under Bill of Entry No. 8207, dated 19.08.1999. They claimed the benefit of concessional rate of duty at 5%, instead of standard 30%, as per the Customs Notification No. 20/1999 and classified the product under Chapter 2309.90 which admittedly pertains to prawn feed. They relied on the ratio in Sun Export Case and claimed the benefit of exemption. The benefit of Customs Notification No. 20/1999 was, however, denied to the respondents on the plea of the department that the goods under import contained chemical ingredients for animal feed and not animal feed/prawn feed, as such, the concessional rate of duty under the extant notification was not available. The department classified the consignment under Chapter 29 which attracts standard rate of customs duty. The adjudicating authority, namely, the Assistant Commissioner of Customs, distinguished Sun Export Case (supra), while accepting the plea of the department to deny the concessional rate. The Commissioner of Customs (Appeals) reversed the order of the Assistant Commissioner and came to the conclusion that Sun Export Case (supra) was indeed applicable. The department then approached the Customs, Excise and Service Tax Tribunal (CESTAT), which affirmed the order of the Commissioner of Customs (Appeals). Aggrieved the assessee filed appeal before the Hon'ble Supreme Court. Under these circumstances, the Hon'ble Supreme Court has held as under:
"52. To sum up, we answer the reference holding as under:
(1) Exemption notification should be interpreted strictly, the burden of proving applicability would be on the assessee to show that his case comes within the parameters of the exemption clause or exemption notification. (2) When there is ambiguity in exemption notification which is subject to strict interpretation, the benefit of such ambiguity cannot be claimed by the subject/assessee and it must be interpreted in favour of the revenue. (3) The ratio in Sun Export case (supra) is not correct and all the decisions which took similar view as in Sun Export Case (supra) stands overruled."ITA No.2985/Chny/2025 (AY: 2018-19)
CEOA Education Society Vs ACIT :- 13 -:
23. However, as mentioned earlier, the Hon'ble Gujarat High Court after considering the decision of the Hon'ble Supreme Court in the case of Wipro Limited (supra) has held that where the assessee had already filed audit report in Form 10B electronically during pendency of appellate proceedings along with copy of audited financial statements, it is sufficient compliance for claiming the exemption u/s 11 of the Act. Since in the instant case the assessee has already submitted the audited report in Form No.10BB during assessment proceedings itself, therefore, the assessee in our opinion is in a better position. The various other decisions relied on by the Revenue as per grounds of appeal or during the course of arguments are distinguishable and not applicable to the facts of the present case. In view of the above discussion, we do not find any infirmity in the order of the Ld. CIT(A) / NFAC allowing the claim of exemption u/s 10(23C)(v) of the Act for belated filing of Form No.10BB. We hold and direct accordingly. The grounds raised by the Revenue are accordingly dismissed.
24. In the result, the appeal filed by the Revenue is dismissed.
5. The ld.AR further referred the order of the Jaipur Bench titled Kinkini Bhilwara ITA No. 1185/JPR/2025 dated 24/12/2025 which held as under:
5. I have heard the rival contentions. The issue before me is the denial of exemption u/s. 11 of the Act to the assessee being a charitable trust on account of delay in filing Form 10BB. As rightly pointed out by the Ld. Counsel for the assessee Hon'ble High Courts and the coordinate Benches of the ITAT have consistently held the requirement of filing Form 10BB to be a mere procedural requirement and not a mandatory condition therefore holding the denial of deduction for the said reason to be not sustainable in law. It has been held that as long as the requisiteform is filed and is made available during assessment proceedings for scrutiny, it is sufficient compliance with the condition of filing Form 10BB and the mere fact of delay in the same would not adversely affect the right of the assessee to claim exemption u/s. 11 of the Act.
In this regard, I draw support from the judgment of the Hon'ble Gujarat High Court in the case of Commissioner of Income Tax (Exemption) vs. Laxmanarayan Dev ShrishanSevaKhendra [2024] 167 taxmann.com 548 (Gujarat) [10.09.2024],wherein it was held at paragraph Nos. 7 & 9 of the order as under:-
7. Reference to the aforesaid decision has no connection whatsoever remotely to the facts of the present case and therefore, in the facts of the present case, the Tribunal has rightly followed the decision of this Court in case of Sarvodaya Charitable Trust v. ITO (Exemption) in Application No.6097 of 2020 decided on 09th December, 2020/[2021] 125 taxmann.com 75/278 Taxman 148 (Gujarat) as well as the decision in case of Social Security Scheme of GICEA (supra) to uphold the decision of the CIT (Appeals), wherein this Court has held that the approach of the authority in such type of cases should be equitable, balancing and judicious. In the facts of the case, when the assessee has already filed the audit report in Form 10B electronically on 27.02.2021 during pendency of appellate proceedings along with copy of audited financial ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 14 -:
statements, delay in filing the said form is rightly condoned by CIT(A) and the Tribunal. ...........................
9. In view of the foregoing reasons, we are of the opinion that no question of law much less any substantial question of law arises from the impugned order of the Tribunal. The Appeal is accordingly dismissed.
6. The Hon'ble Gujarat High Court reiterated this position of law in the case of ParulMahila Pragati Mandal vs. Income-tax Officer (Exemption) [2025] 175 taxmann.com 922 (Gujarat) [30.04.2025]wherein it was held at paragraph Nos. 7.1, 7.2 & 8 of the order as under: -
.........................
"7. DISCUSSION &FINDINGS :-
7.1 In Association of Indian Panel Board Manufacturers v. Dy.CIT [2023] 157 taxmann.com 550 /482 ITR 54 (Gujarat), this Court has categorically held that filing of Form 10B is only a procedural requirement and the failure to file Form 10B along with the return of income cannot be treated as mandatory requirement for the purpose of claiming exemption under Section 11 and 12 of the Act and even if such Form is filed ata later stage, the Assessee will still be entitled to claim exemption. The aforesaid decision in the case of Association of Indian Panel Board (supra) has been followed by this Court in case of CIT (Exemption) v. Anjana Foundation [2024] 168 taxmann.com 462 (Gujarat).
Thus, it will be seen that the Petitioner-Assessee could not be denied the exemption merely because Form 10B was not filed within time. In such circumstances, the denial on the part of the Department to condone the delay in complying with the procedural requirement on the part of the Assessee would result in denial of a substantive right of the Assessee to claim an exemption, which would in turn, result in the Assessee having to pay the demanded amount, thereby unjustly enriching the Department.In such view of the matter in our opinion, the Petitioner would have been caused undue hardship which the Department could have alleviated by allowing the Assessee's application under Section 119(2)(b) of the Act, which is rejected only on the technical grounds.
7.2 This Court in several recent decisions, namely in the case of Royal Led Equipments (P.) Ltd. v. Chief Commissioner of Income- tax [2025] 174 taxmann.com 61 (Gujarat)/Special Civil Application No. 14786 of 2024 and in the case of Surat Smart City Development Ltd. v. Principal Commissioner of Income-tax [2024] 169 taxmann.com 222 (Gujarat)/Special Civil Application No. 10397 of 2024 has directed the Department to consider the Assessee's applications under Section 119(2)(b) of the Act to ensure that the purpose for which the said provision remains on the statute book is carried out and the said provision is not rendered illusory or becomes a dead letter.
8. In view of the aforesaid discussion, the present Petition succeeds and accordingly allowed. The impugned Orders dated 31.03.2021, 30.4.2021 and the Demand Notice dated 06.05.2021 are hereby quashed and set aside. The Respondent No.1 is directed to pass a fresh order upon the Petitioner's application under Section 119(2)(b) of the Act dated 23.02.2021 within a ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 15 -:
period of Twelve (12) weeks from the date of receipt of a copy of this judgment and order in light of the findings in Paragraph Nos. 7.1 to 7.2 hereinabove. Rule is made absolute to the aforesaid extent. No order as to costs.
7. The coordinate Benches of the Tribunal have also consistently held that delayed filing of Form 10BB is a procedural lapse and cannot be the basis for denial of exemption u/s. 11 and 12 of the Act. Reference may be made to decision of the ITAT Ahmedabad Bench in the case of Shree Vardhman Stanakvasi Jain Shravak Trust vs. Income-tax Officer [2025] 172 taxmann.com 165 (Ahmedabad Trib.) [14.02.2025], wherein it was held at paragraph Nos.9, 10, 11 & 12 of the order as under:-
.................................
9. On going through the facts of the instant case, we observe that the adjustments made by CPC have been confirmed by the JCIT(A) on three grounds. Firstly, theassessee had not filed the return of income within the prescribed time limit. Secondly, the assessee had not filed Form 10B within the prescribed time limit.
Thirdly, this addition was permissible by way of adjustment under Section 143(1) of the Act. Therefore, on account of the above reasons, the assessee was not eligible for grant of exemption under Sections 11 & 12 of the Act, and hence the corpus donation was liable to be taxed as income in the hands of the assessee. In response, the Counsel for the assessee submitted before us that in the return of income, it was specifically submitted that such amount of Rs. 17,96,000/- received by the assessee was a voluntary donation and not a corpus donation. Secondly, since the income of the assessee, as per the Profit & Loss account, was below the taxable limit, the assessee trust was not under an obligation to file return of income and therefore, also not an obligation to file Form 10B as well. Thirdly, delayed filing of Form 10B is a procedural defect and since the assessee trust had filed the same before Ld. JCIT(A) during the course of appellate proceedings, no disallowance was called for on account of late filing of said Form 10B.
10. On going through the various adjustments which have been incorporated under Section 143(1) of the Act, we are of the considered view that treatment of such corpus donation as voluntary donation falls outside the scope of adjustments contemplated under Section 143(1) of the Act, unless such incorrect claim is apparent from any information in the return of income. In the return of income filed by the assessee, such donation of Rs. 17,96,000/- was specifically treated as corpus donation and not as voluntary donation. Accordingly, in our considered view, treatment of corpus donation as voluntary donation falls outside the scope of adjustments contemplated under Section 143(1) of the Act. Secondly, we observe that in the case of Shree Swaminarayan Charitable Trust (supra), wherein the ITAT has made the following observations:
"3. The issue before me pertains to delayed submission of Form no.10B which Id.counsel for the stated to be a technical default. He further submitted that ld.Bench of the ITAT, Ahmedabad rejected similar claim in the case ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 16 -:
of Association of Indian Panelboard Manufacturer v. DCIT, ITA No. 24 of 2022. However, the said decision of the ITAT was reversed by the Hon'ble Jurisdictional High Court by judgment dated 21.3.2023 reported in [2023] 157 taxmann.com 550 (Gujarat) holding that w.e.f. Astt.Year 2016-17 filing of form though mandatory in nature but procedural in nature, owing amendment made in Finance Act, 2015. In the present case, however, the ld.counsel for the assessee submitted that the same has been filed subsequently, and therefore, the above decision of the Hon'ble Jurisdictional High Court is squarely applicable. The relevant portion of the judgment of the Hon'ble High Court at para 6.1 is held as under:
6. The moot aspect thus centres around to the requirement of the availability of the audit report when the assessment was undertaken by the Assessing Officer even though the same may not have been filed alongwith (the return of income.
Filing of audit report is held to be substantive requirement but not the mode and stage of filing, which is procedural Once the audit report in Form 12B is filed to be available with the Assessing Officer, before assessment proceedings take place, the requirement of JK law is satisfied. In that view, the Income Tax Tribunal was not justified in dismissing the appeal of the assessee.
6.1 The appellant assessee has to be held to be eligible and entitled to exemptions under section 11(1) and 11 (2) of the Act and. the alleged ground ofnon-filing of audit report alongwith return of income which was at the best procedural omission, could never to an impediment in law in claiming the exemption.
4. On the other hand, the ld.DR relied on the order of the ld.CIT(A).
5. Heard both the parties.
6. I have gone through the record and the orders of the Revenue authorities. Keeping in view the decision of the Hon'ble jurisdictional High Court in the case of Association ofIndian Panel Board Manufactureres (supra), and the assessee having satisfied the requirement of the law, I set aside the impugned orders of the Revenue authorities, and allow the grounds of appeal."
11. The ITAT Ahmedabad in this case has held that delay in submission of Form No. 10B is a procedural defect and once the said Form has been filed during the course of hearing, no disallowance is called for on account of late / delayed filing of Form No. 10B. In the instant case, we observe that the assessee had filed Form No. 10B before Ld. JCIT(A) before conclusion of ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 17 -:
appellate proceedings. Accordingly, in view of the aforesaid decision of Ahmedabad Tribunal, exemption under Sections 11&12 of the Act cannot be denied to the assessee only on account of late filing of Form No. 10B. Accordingly, in light of the above observations, the appeal of the assessee is allowed.
12. In the result, the appeal of the assessee is allowed.
8. In the case of Shree BhaktSamaj Vikas Education Trust vs. Assistant Commissioner of Income-tax (Exemption) [2025] 175 taxmann.com 1076 (Ahmedabad Trib.) [2025] 213 ITD 639 (Ahmedabad-Trib.) [25.06.2025], wherein it was held at paragraph Nos.9, 11 & 12 of the order as under: -
...........................
"9. We observe that admittedly there was a delay on filing Form 10B by the assessee trust. It was on this basis that AO, CPC denied the claim of exemption under Section 11 of the Act. Ld. CIT(A) upheld the denial of exemption under Section 11 of the Act on the ground that despite issuance of multiple notices of hearing, none appeared on behalf of the assessee to present it's case during the course of appellate proceedings. However, we note that it is a well settled law that delay in filing of Form 10B is a procedural default and if other conditions have been met, then mere delay in filing of Form 10B should not disentitle the assessee from claiming exemption under Section 11 of the Act. In the case of Sarvodaya Charitable Trust v. ITO(E) [2021] 125 taxmann.com 75/278 Taxman 148 (Gujarat), the Hon'ble Gujarat High Court held that where assessee, a public charitable trust registered under Section 12A of the Act had substantially satisfied condition for availing benefit of exemption as a trust, it could not be denied exemption merely on bar of limitation in furnishing audit report in Form No. 10B. While passing the order the Hon'ble Gujarat High Court made the following observations:
"31. Having given our due consideration to all the relevant aspects of the matter, we are of the view that the approach in the cases of the present type should be equitious, balancing and judicious. Technically, strictly and liberally speaking, the respondent no. 2 might be justified in denying the exemption under section 12 of the Act by rejecting such condonation application, but an assessee, a public charitable trust past 30 years who substantially satisfies the condition for availing such exemption, should not be denied the same merely on the bar of limitation especially when the legislature has conferred wide discretionary powers to condone such delay on the authorities concerned.
32. We may also refer to the decision of this Court in CIT v. Gujarat Oil and Allied Industries Ltd. [1993] 201 ITR 325 (Guj.), wherein it is held that the provision regarding furnishing of audit report with the return has to be treated as a procedural proviso. It is directory in nature and its substantial compliance would suffice. In that case, the assessee had not produced the audit report along with the return of income but produced the same before the completion of the assessment. This Court took the view that the benefit of exemption should not be denied merely on account of delay in furnishing the same and it is permissible for the assessee to produce the audit report at a later stage either ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 18 -:
before the Income-tax Officer or before the appellate authority by assigning sufficient cause. 33. In view of the above, this writ- application succeeds and is hereby allowed. The impugned order passed by the respondent no. 2 dated 19th August 2019 (Annexure-A to this writ-application) is hereby quashed and set aside. The impugned rectification order at page-13 of the paper-book dated 12th February 2020 is also hereby quashed and set aside. The delay condonation application filed by the writapplicant before the respondent no. 2 is hereby allowed." ............................
11. Accordingly, in view of the decision of the Hon'ble Gujarat High Court in this issue, as well as various other judicial precedents which have upheld the principle that delay in filing of Form 10B being a procedural default should not disentitle the assessee / applicant trust the denial of grant of exemption under Section 11 of the Act, we are of the considered view that in the assessee's set of facts, claim of exemption under Section 11 of the Act should not be denied only on account of delay in filing Audit Report in Form 10B, within the stipulated time. However, we make it clear that we are not making any observations with regard to the merits of the claim of exemption under Section 11 of the Act, but are only allowing the appeal on the legal principle what once Form 10B has been filed by the assessee and the same is available with the Department before passing of order / intimation under Section 143(1) of the Act, then in view of the decisions of Jurisdictional High Court referred to above, the claim of exemption under Section 11 of the Act cannot be denied only on account of delay in filing of Form 10B before the due stipulated date.
12. In the result, the appeal of the assessee is allowed.
9. Ld. DR was unable to draw our attention to any decision of the jurisdictional High Court holding to the contrary. In view of the same respectfully following the binding judicial precedents and having regard to the fact that the audit report in Form 10BB was duly filed and was available on record prior to the issuance of intimation u/s. 143(1)(a) of the Act, I hold that the denial of exemption u/s. 11 of the Act was not justified. In the result, appeal of the assessee is allowed.
6. Before us, Ld. DR relied upon the impugned order. However, she was unable to contradict the above decisions referred.
7. In view of the same respectfully following the binding judicial precedents and having regard to the fact that in the present case, the assessee has demonstrated bona fide conduct by promptly rectifying the error, filing the correct form, and pursuing condonation before the competent authority. In our considered ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 19 -:
opinion, denying exemption solely on account of a procedural lapse would defeat the substantive right of the assessee.
8. In view of the foregoing discussion, we hold that the delay in filing Form No.10BB is a procedural defect. Since the audit report was filed and available during assessment proceedings, the requirement of law stands substantially complied with. The assessee is entitled to exemption under section 10(23C) of the Act. Accordingly, the order of the Ld. CIT(A) is set aside and the Assessing Officer is directed to grant exemption as claimed.
9. In the result, the appeal filed by the assessee is allowed.
Order pronounced in the open court on 15th day of April, 2026 at Chennai.
Sd/- Sd/-
(प ावतीएस) (मनु कुमार िग#र)
(PADMAVATHY S) (MANU KUMAR GIRI)
लेखा सद या /Accountant Member ाियक सद / Judicial Member
#नई/Chennai,
$दनांक/Dated: 15th April, 2026.
SNDP, Sr. PS
आदे शक त%ल&पअ'े&षत/Copy to:
1. अपीलाथ /Appellant
2. थ /Respondent
3. आयकरआयु /CIT, Chennai / Madurai / Salem / Coimbatore.
4. िवभागीय ितिनिध/DR
5. गाडफाईल/GF ITA No.2985/Chny/2025 (AY: 2018-19) CEOA Education Society Vs ACIT :- 20 -: