आयकर अपील(cid:9)य अ(cid:10)धकरण, ‘ए’ (cid:14)यायपीठ, चे(cid:14)नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI (cid:21)ी एबी ट(cid:9) वकti, (cid:14)या(cid:26)यक सद(cid:29)य एव ं (cid:21)ी एस. आर. रघुनाथा, लेखा सद(cid:29)य के सम$

BEFORE SHRI ABY T VARKEY, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.:1444/Chny/2025 (cid:26)नधा%रण वष % / Assessment Year: 2019-20 ACIT, Chettinad Academy of Research Central Circle -3(2), vs. and Education, Chennai. 603, Chettinad Towers, Anna Salai, Chennai – 600 006.

[PAN:AAATC-8714-H]

(अपीलाथ’/Appellant) (()यथ’/Respondent)

अपीलाथ’ क* ओर से/Appellant by : Ms. E. Pavuna Sundari, C.I.T.

()यथ’ क* ओर से/Respondent by : Shri. N. Arjun Raj, Advocate सुनवाई क* तार(cid:9)ख/Date of Hearing : 11.09.2025 घोषणा क* तार(cid:9)ख/Date of Pronouncement : 25.11.2025 आदेश /O R D E R PER S. R. RAGHUNATHA, AM :

The present appeal is filed by the revenue being aggrieved by order of the Ld. Commissioner of Income Tax (Appeals) Chennai – 20 (in short ‘Ld.CIT(A)) dated 26.03.2025 in Appeal No.CIT(A), Chennai - 18/10926/2018-

19 for the Assessment Year 2019-20.

2. The brief facts of the present case are that the assessee is a Charitable Trust registered u/s.12AA of Income Tax Act, 1961 (in short ‘the Act’) in F.No.DIT(E)No.2(17)/07-08 in the file of the then Director of Income Tax(Exemptions), Chennai dated 10.10.2007.

3. The assessee trust for the assessment year 2019-20 had filed its return of income u/s.139(1) Act on 30.10.2019 in declaring Total income at Rs.Nil after claiming exemption u/s.11 of Act. It is also seen that the assessee had filed Form No.10 30.10.2019 by seeking accumulation of funds in terms of Section

11(2)(a) of the Act to the extent of Rs.11,22,95,380/-.

4. The Income Tax Department had conducted search and seizure action u/s.132 of the Act on 09.12.2020 in the case of Chettinad Group, wherein the assessee herein was also searched.

5. The Assessing Officer (AO) had accordingly issued notice u/s.153A of Act on 16.08.2021. The assessee in response to the same had filed its return of income for the on 21.01.2022 in declaring taxable total income at Rs. Nil after claiming exemption u/s.11 of Act.

6. The AO had thereafter issued notice u/s.143(2) of the Act and notice(s) in terms of Section 142(1) of the Act in calling for details in support of the return of income filed for the A.Y. under consideration.

7. The AO during the course of search assessment proceedings had issued a Show Cause Notice in proposing to disallow a sum of Rs.13,74,25,896/-, being the revenue expenditure claimed on account of income tax paid as the said sums were not applied for the purpose of charitable activity.

8. The assessee in response to the said Show Cause Notice had submitted that the said amount had been claimed as application inadvertently and requested that the same to be considered as accumulation and to be utilized for the objects of the trust u/s.11(2)(a) of the Act.

9. The assessee in support of the above submissions had filed a revised Form 10 on 14.03.2022 in seeking accumulation to the extent of Rs.13,74,25,896/- as against the original Form No.10 filed on 30.10.2019 in seeking accumulation to the extent of Rs.11,22,95,380/-. However, the AO had rejected the revised Form No.10 filed on 14.03.2022 by holding that the same was not filed within the stipulated time limit u/s.139(1) of the Act and proceeded to disallow a sum of Rs.13,74,25,896/- debited in the Income & Expenditure account and accounted for as application towards charitable purposes and computed the same as income in hands of the assessee trust vide search assessment passed u/s.153A of the Act dated 31.03.2022 by determining the taxable total income at Rs.11,88,16,000/-.

10. The assessee trust aggrieved by the said search assessment order dated

31.03.2022, had challenged the same before the Ld.CIT(A).

11. The assessee during the course of appellate proceedings had contended that it was not case of a taxpayer filing fresh /