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2025 Supreme(Online)(ITAT) 7017

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
FOUNDATION FOR UNIVERSAL RESPONSIBILITY OF HIS HOLINESS THE DALAI LAMA DELHI – Appellant
Versus
ITO EXEMP. WARD-1(1) DELHI – Respondent


Table of Content
1. appellant's appeal against tax order. (Para 1 , 2)
2. arguments on accumulated funds tax amendment. (Para 3 , 4 , 5)
3. court's review of law amendments and decisions. (Para 6)
4. court allows appeal, directs deletion of tax adjustment. (Para 8)

आदेश /ORDER

PER C.N. PRASAD, J.M.

This appeal is filed by the Assessee against the order of the Ld. Addl./JCIT (Appeals), Chandigarh dated 27.02.2025 for the AY 2023- 24 in sustaining the addition made by the Assessing Officer/CPC in respect of adjustment on account of non utilization of accumulated funds.

2. Ld. Counsel for the assessee submitted that this appeal is filed against the order of the Ld. CIT(A) in confirming the addition of Rs.1,38,45,266/- made by AO/CPC u/s 115BBI of the Act. Ld. Counsel for the assessee submits that assessee is a charitable trust registered u/s 12A of the Act and claiming exemption u/s 11(2)(13) of the Act. During the assessment year under consideration, the assessee filed its return of income on 30.10.2023 declaring Nil income and the AO/CPC processed the intimation u/s 143(1) of the Act on 30.10.2023 making an adjustment of Rs.1,38,45,266/- on account of non-utilization of accumulated funds. I

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