आयकर अपील(cid:547)य अ(cid:876)धकरण, चÖडीगढ़ Ûयायपीठ, चÖडीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL CHANDIGARH BENCH, ‘A’, CHANDIGARH BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER &

SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 237/CHD/2020 (cid:467)नधा(cid:91)रण वष(cid:91) / Assessment Year : 2014-15 Haryana Building and Other The DCIT, Construction Workers बनाम Circle 2, Welfare Board, Bays No. 29- Vs. Exemption, 30, Sector 4, Panchkula, Chandigarh Haryana èथायी लेखा सं./ PAN NO: AAATH6995H अपीलाथ(cid:568)/Appellant (cid:292)×यथ(cid:568)/Respondent आयकर अपील सं./ ITA Nos. 337 to 339/CHD/2023 (cid:467)नधा(cid:91)रण वष(cid:91) / Assessment Years : 2016-17, 2017-18 & 2018-19 Haryana Building and Other The DCIT Construction Workers बनाम Exemption, Welfare Board, Bays No. 29- Vs. Chandigarh

30, Sector 4, Panchkula, Haryana èथायी लेखा सं./ PAN NO: AAATH6995H अपीलाथ(cid:568)/Appellant (cid:292)×यथ(cid:568)/Respondent आयकर अपील सं./ ITA No. 63/CHD/2021 (cid:467)नधा(cid:91)रण वष(cid:91) / Assessment Year : 2015-16 Haryana Building and Other The DCIT Construction Workers बनाम Exemptions, Welfare Board, Vs. Chandigarh Bays No. 29-30, Sector 4, Panchkula, Haryana èथायी लेखा सं./ PAN NO: AAATH6995H अपीलाथ(cid:568)/Appellant (cid:292)×यथ(cid:568)/Respondent ( PHYSICAL HEARING )

(cid:467)नधा(cid:91)(cid:464)रती क(cid:551) ओर से/Assessee by : Sh. Nikhil Goyal, Advocate, Sh. Ashok Goyal, CA and Sh. Sifatfreet Singh, CA राजèव क(cid:551) ओर से/ Revenue by : Sh. Manav Bansal, CIT DR सुनवाई क(cid:551) तार(cid:547)ख/Date of Hearing : 08.12.2025 उदघोषणा क(cid:551) तार(cid:547)ख/Date of Pronouncement : 10.12.2025 आदेश/Order Per Bench:

The captioned appeals preferred by the assessee are directed against the separate orders of the Ld. Commissioner of Income- tax (Appeals) for different assessment years, as per the details given below:

2. From the records, it is noticed that the appeals in ITA Nos.

337 to 339/Chd/2023 are filed belatedly by one day in each case. The Ld. Counsel for the assessee has submitted an application praying for condonation of delay giving identical reasons in each case which is reproduced as under:

3. We have considered the contents of application and submission made for condonation of delay and we feel it appropriate to condone the delay in the appeals in question.

4. The ld. DR had no objection for condonation of delay.

5. Since the issue involved in all the appeals are identical, (except in ITA No. 673/Chd/2021 for AY 2015-16) wherein, the order had been passed u/s 263 of the I.T. Act by CIT Exemptions, Chandigarh, therefore, these appeals were heard together and are disposed off for the sake of brevity.

6. Appeal of the Assessee for A.Y. 2014-15 in ITA No 339/Chd/2023 is taken as a lead case, wherein, the grounds raised by the Assessee are as under:

1. That the order passed by the Ld. Commissioner of Income tax (Appeals), National Faceless Appeal Centre, Delhi is erroneous, devoid of merits, has been passed in haste without taking into consideration the facts of the case and submissions made and the same deserves to be quashed.

2 That the First Appellate Authority has erred both on facts and law in holding that the appellant was engaged in the activities for general public utility and accordingly holding that exemption provisions of section 11 and 12 can not be applied to the case of the Appellant. These observations and findings are based upon incorrect understanding of the facts and by ignoring the orders of the Hon'ble Income Tax Appellate Tribunal, Chandigarh Bench, Chandigarh who clearly held that the appellant was engaged in the activities of welfare of poor.

Necessary directions in this regard may be given and the observations of the Ld. Commissioner of Income tax (Appeals), National Faceless Appeal Centre, Delhi that the appellant was engaged in carrying out objects of general public utility may be ordered to be quashed and consequential relief arising therefrom may kindly be ordered.

3. That the First Appellate Authorit