, , आयकरअपीलीयअिधकरण इंदौर(cid:586)ायपीठ इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M. JOSHI, JUDICIAL MEMBER ITA No.164/Ind/2018 (Assessment Year:2014-15)

Board of Secondary DCIT(Exemption)

Education, Bhopal /

बनाम Shivaji Nagar, Vs.

Bhopal (Revenue/Appellant) (Assessee/Respondent)

PAN: AAAJB1143R Assessee by Shri Arpit Gaur, AR Revenue by Shri Ashish Porwal, Sr. DR Date of Hearing 25.11.2025 Date of Pronouncement 03.12.2025 आदेश /O R D E R Per B.M. Biyani, A.M.:

Feeling aggrieved by order of first appeal dated 19.12.2017 passed by learned Commissioner of Income-Tax (Appeals)-3, Bhopal [“CIT(A)”] in Appeal No. CIT(A)-2/BPL/IT-638/16-17, which in turn arises out of assessment-order dated 30.12.2016 passed by learned DCIT (Exemption), Bhopal [“AO”] u/s 143(3) of Income-tax Act, 1961 [“the Act”] for Assessment- Year [“AY”] 2014-15, the assessee has filed this appeal raising effective ground as under:

“1. On the facts and in the circumstances of the case, the Learned Commissioner of Income Tax (Appeals-II), Bhopal was notjustified in holding thatthe paymentof Income Tax ofRs. 2,16,50,650/- paid on deemed income u