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INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
DR. BRR KUMAR, VP, SHRI SIDDHARTHA NAUTIYAL, J
DUDHSAGAR RESEARCH AND DEMENT ASSOCIATION MEHSANA – Appellant
Versus
THE DY.CIT CICLE-1 EXEMPTION AHMEDABAD – Respondent
| Table of Content |
|---|
| 1. assesse's claim for tax exemption based on charitable activities. (Para 3 , 4 , 5) |
| 2. court's rationale for verifying voluntary contribution definitions. (Para 6 , 7 , 8) |
| 3. application of statutory provisions for eligible deductions. (Para 9 , 10) |
| 4. overall ruling on appeal's eligibility for partial exemption. (Para 11 , 12 , 13) |
ORDER
PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER:
These 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 order dated 27.11.2024 passed for A.Ys. 2016-17 & 2017-18.
2. The assessee has raised the following grounds of appeal:
ITA No. 202/Ahd/2025 (A.Y. 2016-17)
“1.1 The order passed by U/s.250 passed on 27.11.2024 for AY 2016-17 by NFAC, [CIT(A)], Delhi (for short CIT(A)” upholding the activity of sale of semen doze by the appellant trust was covered under proviso to Sec. 2(15) being the object of general public utility, the exemption u/s 11&12 were not admissible and sec. 13(8) was applicable as well as treating the corpus donation amounting to Rs. 7,45,56,979/- as revenue receipt so that sec.11(
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