IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER &

SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. No.2330/Ahd/2025 (Assessment Year: 2017-18)

Assistant Commissioner of Vs. Shri Khodal Dham Trust Kagvad Income Tax (Exemption), 4^th Floor, Shree Sardar Patel Circle-2, Bhavan, Alka Society, Nr. Water Ahmedabad Tank, New Mayani Nagar, Rajkot-360001 [PAN No.AAJTS1017J]

(Appellant) .. (Respondent Appellant by : Shri Mehul Ranpura, AR Respondent by: Shri Rameshwar P Meena, Sr. DR Date of Hearing 25.03.2026 Date of Pronouncement 23.04.2026

O R D E R

PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: This appeal has been filed by the Department against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi vide order dated 11.09.2025 passed for A.Y. 2017-18.

2. The Department has raised the following grounds of appeal: “1. Whether on the facts and in circumstances of the case, Ld. CIT(A), NFAC is justified in deleting the addition of Rs. 3,40,68,567/- (11529801 plus 22538766) made on account of expenditure being non charitable in nature for the year under