IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “SMC” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER &

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2016-17]

B.R. Morden School Samiti vs ITO Tara Lodge, Exemption, Tehsil Road Pauri, Pauri, Ward Dehradun Uttarakhand-246001.

PAN-AACAB6988M APPELLANT RESPONDENT Appellant by Shri Rajiv Sahni, CA Respondent by Shri Amar Pal Singh, Sr.DR Date of Hearing 11.03.2026 Date of Pronouncement 13.03.2026

ORDER

PER MANISH AGARWAL, AM :

The present appeal is filed by assessee against the order dated

27.11.2025 passed by Ld. Commissioner of Income Tax (A), NFAC, Delhi [“Ld. CIT(A)”] u/s 250 of the Income Tax Act, 1961 [“the Act”] against the order dated 07.12.2018 passed u/s 143(3) Of the Act pertaining to Assessment Year 2016-17.

2. Before us, Ld.AR for the assessee submits that as per section 10(23C)(iiiad), annual receipts are to be considered for the purposes of allowing exemption to the educational institutions. Ld.AR submits that AO has wrongly considered gross receipts which includes voluntarily towards building fund as part of annual receipts to deny the exemption available u/s 10(23C)(iiiad) of the Act to the assessee.

F