IN THE INCOME TAX APPELLATE TRIBUNAL PATNA ‘DB’ BENCH AT KOLKATA [Virtual Court]

Before SHRI SONJOY SARMA, JUDICIAL MEMBER &

SHRI RAKESH MISHRA, ACCOUNTANT MEMBER ITA No.: 14/PAT/2018 Assessment Year: 2014-15 Society for Advancement of ACIT(Exemption), Circle-

Village Economy Vs. Patna (Appellant) (Respondent)

PAN: AAJTS1557R Appearances:

Assessee represented by : Dipak Kumar, CA.

Department represented by : Md. Shadab Ahmed, CIR(DR).

Date of concluding the hearing : 14-October-2025 Date of pronouncing the order : 09-December-2025

ORDER

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals)-I, Patna [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250(6) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2014-15 dated 24.11.2017.

2. The assessee is in appeal before the Tribunal raising the following grounds of appeal:

“1. FOR THAT Ld. CIT(A) erred in law and on the facts in confirming action of A.O. in holding that the appellant trust carried on activity in the nature of business and profession under the guise of Trust Act, 1882. Ld. CIT (A) ought to have held that the appellant trust