आयकर अपील(cid:547)य अ(cid:876)धकरण Ûयायपीठ रायपुर म(cid:581)।

IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI ARUN KHODPIA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.176/RPR/2018 CO No.15/RPR/2018 (cid:467)नधा(cid:91)रण वष/(cid:91) Assessment Year : 2014-15 The Assistant Commissioner of Income Tax (Exemption)

Raipur (C.G.)

.......अपीलाथ(cid:568) / Appellant बनाम / V/s.

M/s. All India Society for Electronics &

Computer Tech. C-18, Sector-1, Avanti Bihar, Raipur (C.G.)

PAN: AABAA7258C ……(cid:292)×यथ(cid:568) / Respondent Assessee by : Shri R.B Doshi, CA Revenue by : Shri S.L Anuragi, CIT-DR सुनवाई क(cid:551) तार(cid:547)ख / Date of Hearing : 31.01.2025 घोषणा क(cid:551) तार(cid:547)ख / Date of Pronouncement : 28.02.2025 आदेश / ORDER PER BENCH:

The captioned appeal filed by the revenue is directed against the order passed by the Commissioner of Income Tax (Appeals)-1, Raipur, [in short “Ld.CIT(A)”], dated 08.06.2018 for the Assessment Year 2014-15, which in turn arises from the order passed by the Assistant Commissioner of Income Tax (Exemption), Circle-Raipur u/s. 143(3) of the Act dated 31.12.2016, wherein the impugned order has been assailed on the following grounds of appeal:

Grounds of appeal in ITA No.176/RPR/2018

1. "Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) was justified in allowing the exemption u/s10(23C)(vi) to the assessee when the same was not claimed in return of income filed.

2. “Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) was justified in allowing the exemption u/s 11/12AA when the assessee failed to substantiate the genuineness of the expense and payment on account of these inflated expenses diverted to related concerns.”

3. "Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) was justified in allowing claim u/s 11 & 10(23C)(iv) of the addition of Rs.54,16,704/- made on account of excessive salary, which was disallowed on contravening the provisions of sections of 13(1)(c), 13(2)(c) and 13(2)(g) of the I.T. Act, 1961 read with section 13(3) by the assessee resulting into forfeiture of the exemptions u/s11 and 12 of the I. T. Act."

4. “Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) was justified in deleting the addition of Rs.1,71,64,553/- made on account of surplus income of the assessee when the trust fund were diverted to related concerns by inflating expenses under various heads which resulted into withdrawal of exemption u/s.11.”

5. "Whether on points of Jaw and on facts & circumstances of the case, the Ld. CIT(A) was justified in deleting the addition of Rs.2,94,41,280/- made on account of students data processing expenses, giving a finding which is contrary to the evidence on record and which was found not true on verification by the AO?”

6. "Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) was justified in deleting the addition of Rs.1,37,458/- made on account of V. C. House expenses as being personal in nature?

7. “Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) was justified in deleting the addition of Rs.3,20,74,537/- made on account of advertisement expenses, giving a finding which is contrary to the evidence on record and which was found not true on verification by the AO?".

8. "Whether the Ld. CIT(A) was correct in law and facts in allowing the addition of Rs. 14,56,75,819/- ignoring the findings by the A.O. that such fund collected by the assessee is not qualified for exemption u/s 11(1)(d) of the Act”.

9. “Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) was justified in deleting the addition of Rs.41,95,800/- made on account of computer & software expenses, giving a finding which is contrary to the evidence on record and which was found not true on verification by the AO?”.

10. "Whether on points of law and on facts & c