IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER &

HON’BLE SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA No. 179/Mum/2025 (Assessment Year: 2015-16)

Credit Guarantee Fund Vs. DCIT(E) – 1(1)

Trust Mumbai.

1^st Floor, Sidbi Swavalaman Bhavan, Avenue – 3, Lane 2, G-Block, BKC, Bandra (E)

PAN/GIR No. AAATC2613D (Applicant) (Respondent)

Assessee by Shri Bhupendra Karkhanis & Jay Dharod Revenue by Mr. R.A. Dhyani, CIT DR Date of Hearing 24.02.2025 Date of Pronouncement 06.03.2025 आदेश / ORDER PER SANDEEP GOSAIN, JM:

The present appeal has been filed by the assessee challenging the impugned order 02.12.2024 passed u/s 12AA of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre, Delhi / CIT(A), Mumbai, for the A.Y 2015-16

2. The brief facts of the case are that the assessee has filed the return of income for the year under consideration declaring loss, however regular assessment u/s 143(1) of the Act was completed thereby assessing total income of Rs. 93,73,75,000/- by making the addition of the said amount being the contribution from settlers to the corpus of trust by treating the same as voluntary contribution u/s

2(