IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “B” BENCH : PUNE BEFORE SHRI RAMA KANTA PANDA, VICE-PRESIDENT &

Ms. ASTHA CHANDRA, JUDICIAL MEMBER I.T.A.No.928/PUN/2025 (Assessment Year : 2021-2022)

(Assessment Year : 2021-2022)

(Assessment Year : 2021-2022)

(Assessment Year : 2021-2022)

(Assessment Year : 2021-2022)

(Assessment Year : 2021-2022)

(Assessment Year : 2021-2022)

(Assessment Year : 2021-2022)

For Assessee : Shri C.H. Naniwadekar, CA For Revenue : Shri Udaya Bhaskar Jakke, CIT Date of Hearing : 11.11.2025 Date of Pronouncement : 01.01.2026

ORDER

PER : ASTHA CHANDRA, JM This appeal filed by the Revenue is directed against the order of ADDL/JCIT (Appeals)-1, Guwahati [“CIT(A)”] dated 05/02/2025 pertaining to the Assessment Year (“AY”) 2021-22.

2. Briefly stated, the facts are that assessee is a charitable trust engaged in running educational institutions. It is registered under the Societies Registration Act, 1860 and the Bombay Public Trust Act, 1950. It is also registered u/s. 12A and 80G of the Income Tax Act, 1961 (“Act”). For A.Y. 2021-22, assessee filed its return of income on 30/12/2021 declaring total income of ₹36,460/- after claiming exemption u/s. 11 of the Act. The audit repo