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2024 Supreme(Online)(ITAT) 278

INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
SHRI CHANDRA POOJARI, AM, SMT. MADHUMITA ROY, JM
SANGHAMITRA RURAL FINANCIAL SERVICES BANGALORE – Appellant
Versus
ASSISTANT COMMISSIONER OF INCOME TAX EXEMPTIONS CIRCLE-1 BANGALORE – Respondent


Advocates:
For the Appellants/Petitioners: Shri Ravishankar, A.R.
For the Respondents: Shri D.K. Mishra, D.R.

ORDER

PER CHANDRA POOJARI, ACCOUNTANT MEMBER:

These appeals by assessee are directed against different orders of NFAC for the assessment years 2016-17 & 2017-18. The assessee has raised common grounds of appeal, which are as follows:

“1. The orders of the authorities below in so far as they are against the appellant is opposed to law, weight of evidence, probabilities, facts and circumstances of the Appellant's case.

2. The appellant denies itself to be assessed at Rs. 7,08,37,639/- as against the returned income of Rs.NIL for the assessment year 2018-19 under the facts and circumstances of the case.

3. The learned CIT(A) is not justified in upholding the disallowance of the exemption claimed under section n of the Act, on the ground that the activities of the appellant are hit by the proviso to section 2(15) of the Act on the facts and circumstances of the case.

4. The authorities below failed to appreciate that the activities of the appellant fell under "relief to poor" and thus charitable, on the facts and circumstances of the case.

5. The authorities below were not justified in holding that the activity of providing financial assistance to poor people would fall within the limb "advan

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