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2025 Supreme(Online)(ITAT) 5441

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
Siddhartha Nautiyal, J, Makarand V. Mahadekar, ACJ
Ash Education Trust – Appellant
Versus
Commissioner of Income Tax (Appeals) – Respondent


Advocates:
For the Appellant: Shri Mehul Thakkar, AR
For the Respondent: Dr. Sanjay Kumar Lal, CIT DR

Table of Content
1. counsel's arguments regarding procedural defaults and exemptions. (Para 2 , 5 , 6 , 10)
2. overview of appellant's filed return results. (Para 3)
3. denial of exemption relies on procedural defaults. (Para 4 , 8)

ORDER

PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER:

Both appeals have been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi vide orders dated 22.08.2024 passed for A.Ys. 2013-14 & 2014-15. Since common facts and issues for consideration are involved for both the years under consideration, both appeals filed by the assessee are being taken up together.

2. The assessee has raised the following grounds of appeal:

ITA No. 1830/Ahd/2024 (A.Y. 2013-14)

“1. Ld. Commissioner of Income Tax (Appeals), Income Tax Department erred in law and on facts while passing the impugned Order and dismissing the appeal filed by the Appellant.

2. Ld. Commissioner of Income Tax (Appeals), Income Tax Department was not justified in deciding that there was no mistake in processing of the return of income despite of fact that the return of income was processed witho

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