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2025 Supreme(Online)(ITAT) 4961

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
T.R. Senthil Kumar, J, Narendra Prasad Sinha, ACJ
SHRI KRISHNANAGAR VAISHNVSAMAJ BHAVNAGAR – Appellant
Versus
THE ITO (EXEMPTION) BHAVNAGAR – Respondent


Advocates:
For the Appellants/Petitioners: Shri Manas Rindani
For the Respondents: Smt. Mamta Singh

Table of Content
1. overview of the appeal and facts regarding the trust's income. (Para 1 , 2)
2. arguments concerning the effects of legislative amendments. (Para 3 , 4 , 5 , 6)
3. court's observations on the implications of amendment for the trust. (Para 7)
4. final ruling in favor of the appellant, allowing the appeal. (Para 8)

ORDER

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

This appeal is filed by the assessee against the order of National Faceless Appeal Centre (NFAC) [hereinafter referred as ‘CIT(A)’] dated 29.03.2025 for the Assessment Year (A.Y.) 2023-24 in the proceeding under Section 143(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

2. The brief facts of the case are that the assessee had filed its return of income for the A.Y. 2023-24 on 09.10.2023 declaring income of Rs.5,38,930/-. The assessee is a Trust eligible for deduction under Section 11 of the Act. The assessee had accumulated an amount of Rs.4,60,000/- in the Financial Year 2016-17 which was required to be utilised within a period of five years as provided under Section 11 (2) of the Act. In the return of income for the A.Y. 2023-24, the assessee had shown utilisation of Rs.2,32,073/-

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