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4. At the outset, the ld. Counsel for the assessee has
contended that he wishes to withdraw Ground no.2 originally
raised in the Grounds of appeal as well as the Additional
Grounds. Therefore, Ground no.2 as well as the Additional
Grounds raised by the assessee are rejected as withdrawn. Now
we are left with only Ground no.1, challenging the order of the ld.
CIT(A) in sustaining the addition of Rs.28,50,000/-.
5. The brief facts of the case are that the assessee is a
Charitable Trust registered under section 12A of the Income Tax
Act, 1961; that the return of income for the year under
consideration was filed on 21.7.2010, declaring NIL income; that
the assessment was completed under section 143 (3) of the Act at
an income of Rs.1,27,46,700/- after making addition under
section 115 BBC of the Act; that aggrieved by the order of the
Assessing Officer, the assessee preferred an appeal before the ld.