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INCOME TAX APPELLATE TRIBUNAL (PUNE BENCH)
R.K. Panda, Vice-President, Astha Chandra, Judicial Member
Prof. J.P. Trivedi Memorial Trust – Appellant
Versus
ITO Exemption, Ward-1(1), Pune – Respondent
| Table of Content |
|---|
| 1. assessee trust's background and exemption claim under section 11(2) (Para 1 , 2) |
| 2. lower authorities' denial for non-compliance with section 11(2)(a) and form 10 (Para 3 , 4) |
| 3. assessee's arguments on resolution and precedents condoning form 10 delay (Para 5 , 6) |
| 4. tribunal's review of facts and assessee's resolution for accumulation purpose (Para 7 , 8) |
| 5. precedents allowing exemption despite non-specification or delay in form 10 (Para 9 , 10 , 11) |
| 6. allowing assessee's exemption claim under section 11(2) for both ays (Para 12 , 13 , 14 , 15) |
आदेश/ORDER
PER ASTHA CHANDRA, JM :
The above two appeals filed by the assessee are directed against the separate orders both dated 13.08.2025 of the Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi [“CIT(A)/NFAC”] pertaining to Assessment Years (“AYs”) 2017-18 and 2018-19. Since identical issues are involved in both the appeals, for the sake of convenience, these appeals were heard together and are being disposed of by this common order.
ITA No. 2147/PUN/2025, AY 2017-18
2. Briefly stated, the facts of the case are that the assessee is a charitable trust registered under the Bombay Public Trust Act, 1950. It is engaged in a
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