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Appeal in this case has been filed by the assessee against the order dated 22.10.2204 of Ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi for A.Y. 2015-16.

2. Grounds of appeal are as under:

1140-c-2024 -

Tika Ram Educational Society, Sonepat

1. That learned CITA (NFAC) has erred in law and facts in confirming the action of learned AO for reopening of assessment u/s 148

Tika Ram Educational Society, Sonepat

7. The appellant craves leave to add to or amend the aforesaid grounds before disposal of the appeal

3. Facts of the case, as per the order of the Ld. CIT(A), are as under:-

1. Assessee is an Education Society formed in 1934 after getting land and building from Government and thereafter land was allotted in 1951,1975,1992 by State Government of Punjab, Haryana. The Institutions are substantially financed by the Government for the last more than 80 years. The society was formed by a freedom fighter Shri Tika Ram for the cause of education. The fees charged from students is around Rs.200-600 per month at present.

2. That 95 percent of salary of teaching and non-

teaching staff of colleges and 75 percent of the schools are reimbursed during the year for the various institutions run by Assessee.

3. That return of Income was filed on 31-3-2017 claiming exemption u/s10(23C) (iiiab) on the strength of revenue grant of 9.74 crore (48.34 1140-c-2024 -

Tika Ram Educational Society, Sonepat percent) against Gross receipt of 20,15 crore. Apart from revenue grant, Government has granted 21 acres of land in the heart of city which is worth Rs.28.23 crore as per certificate of Tehsildar placed on records. Thus, if total grant of Government is considered which comprise cash grant as well as land, grant is more than 50 percent of Gross receipts.

7. That due to system glitches of Income Tax Website, assessee could not file the return of Income which was informed to all possible platforms through grievances and the error was rectified by Technical Team of Income Tax 1140-c-2024 -

Tika Ram Educational Society, Sonepat Department and immediately thereafter the return of Income was filed and verified.