IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE – PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos. 3099-3101/Bang/2025 Assessment Years: 2015-16, 2016-17 & 2017-18 M/s. Deshpande Educational Trust, DCSE Building, BVB CET Campus, The DCIT (Exemptions), Vidyanagar, Hubli, Circle – 1, Karnataka – 580 031. Vs.

Mangalore.

PAN: AABTD4450G APPELLANT RESPONDENT Assessee by : Shri L. Bharath, CA Revenue by : Shri Balusamy N – JCIT Date of Hearing : 16-03-2026 Date of Pronouncement : 15-04-2026

ORDER

PER PRASHANT MAHARISHI, VICE – PRESIDENT

1. These are three appeals of the appellant involving similar issue, arguments advanced are also same, so disposed of by this common order.

2. Taking first appeal for AY 2015-16 , ITA No. 3099/Bang/2025 is filed by M/s.

Deshpande Educational Trust (the Assessee/Appellant) for Assessment Year 2015-16 against the Appellate Order passed by the National Faceless Appeal Centre, Delhi (the Ld. CIT(A)) dated 15.10.2025 wherein the Appeal filed by the Assessee against the Assessment Order passed on 29.03.2022 u/s. 147 r.w.s.

144B of the Income Tax Act, 1961 (the Act) dated 29.03.2022, was dismissed. 3. The Assessee is in appeal before us raising following grounds of appeal: -

i. On the facts and in the circumstances of the case, the orders passed by the Learned Assessing Officer (LAO) and the Honourable Commissioner of income-tax (Appeals) ('Hon'ble CIT(A)') are bad in law to the extent they are prejudicial to the Appellant since the same were undertaken without appreciating the Appellant's submissions.

ii. The Hon'ble CIT(A) erred in upholding the disallowances made by the LAO without considering that the same is not in accordance with the provisions of the Act to the extent they are prejudicial to the Appellant since the order is against the provisions of the Income tax Act, 1961 ('the Act') and the judicial precedence on the subject iii. a. The LAO erred in law and fact by concluding that the activities carried on by the Appellant do not constitute 'education' and therefore is not a 'Charitable activity' under section 2(15) of the Act; the Hon'ble CIT(A)

erred in sustaining the same.

b. The LAO has erred in holding that the Appellant has not undertaken any activity in the area of formal education; the Hon'ble CIT(A) erred in sustaining the same.

c. The LAO has erred in holding without any basis that the programmes conducted by the Appellant is run by private persons for profit; the Hon'ble CIT(A) erred in sustaining the same.

d. The LAO has erred in holding that the Appellant has not undertaken any activity in the area of education without considering that the Appellant-Trust's objectives which consistently emphasise this aspect and the Appellant-Trust's activities have been fully aligned to these objects; the Hon'ble CIT(A) erred in sustaining the LAO's action without considering these aspects.

e. Without prejudice to the preceding grounds, the LAO erred in law and fact by concluding that the activities carried on by the Appellant do not constitute 'relief for the poor’ under section 2(15) of the Act, the Hon'ble CIT(A) erred in sustaining the same.

iv. Without prejudice to the above, the LAO has erred in holding that the objective of the activities of the Appellant are of advancement of general public utility as provided u/s 2(15) of the Act, the Hon'ble CIT(A) erred in sustaining the same.

v. The LAG has erred in holding that the activities of the Appellant constitute trade, commerce or business and that it is engaged in commercial activities, the Hon'ble CIT(A) erred in sustaining the same.

vi. The LAO has erred in holding that the activities of the Appellant are undertaken with a profit motive without considering that for the impugned year, the Appellant has a deficit in its Income & Expenditure account the Hon'ble CIT(A) erred in sustaining the same.

vii. The LAO has erred in denying the claim of exemption under section 11 of the Act amounting to Rs. 1,50,60,86