ORDER

PER SOUNDARARAJAN K., JUDICIAL MEMBER

This is an appeal filed by the revenue challenging the order of the NFAC, Delhi dated 27/09/2024 in respect of the A.Y. 2021-22 and raised the following grounds:

“1. The Order of the Ld.CIT(A) is opposed to facts and circumstances of the case.

2. Whether on the facts and in the circumstances of the case, the Ld.CIT(A) is correct in law in allowing the appeal of assessee despite the fact that assessee had only claimed exemption of Rs.4,89,42,007/- as against the total receipts of Rs.48,94,20,072/- under section 10(23AAA) of the Income Tax Act, 1961?

3. Whether on the facts and in the circumstances of the case, the Ld.CIT(A) is correct in law in allowing the appeal of assessee by ignoring the fact that the difference of Total Receipts and exemption claimed under section 10(23AAA) of the Income Tax Act, 1961, has to be brought to tax?

4. The appellant craves leave to add, alter or amend all or any of the grounds of Appeal before or at the time of the hearing of the appeal.

5. The order of the learned CIT(A) may be set-aside and the order of the ADIT, CPC may be confirmed.”

2. The assessee is a trust established for the welfare of the employees of th