आदेश / ORDER

PER ASTHA CHANDRA, JM :

The appeal filed by the Revenue is directed against the order dated 06.08.2025 of the Ld. Additional/Joint Commissioner of Income Tax (Appeals)-5, Kolkata [“Addl./JCIT(A)”] pertaining to Assessment Year (“AY”) 2020-21.

2. Briefly stated, the facts of the case are that the assessee is a registered charitable trust and engaged in carrying out educational activities. It is registered u/s 12A/12AA of the Income Tax Act, 1961 (the “Act”). For AY 2020-21, the assessee filed its return of income on 30.03.2021 u/s 139 of the Act declaring taxable income at Rs.Nil after claiming exemption u/s 11 of the Act. The assessee also filed Form 10B on 30.03.2021 along with the return of income. The return of income was processed u/s 143(1) of the Act vide intimation order passed on 24.12.2021. The Central Processing Center/the Ld. Assessing Officer (“CPC/AO”) denied the claim of exemption u/s 11 of the Act without assigning any reason for such denial and considered the gross income of Rs.5,60,34,363/- as taxable income without considering any expenses. As no specific reason for denial of claim of exemption has been assigned by the Ld. CPC/AO it is alleged that the s