आयकर अपील(cid:9)य अ(cid:10)धकरण, ‘ए’ (cid:14)यायपीठ, चे(cid:14)नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI (cid:21)ी एबी ट(cid:9) वकti, (cid:14)या(cid:26)यक सद(cid:29)य एव ं (cid:21)ी एस. आर. रघुनाथा, लेखा सद(cid:29)य के सम$

BEFORE SHRI ABY T VARKEY, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.:1568/Chny/2025 (cid:26)नधा%रण वष % / Assessment Year: 2020-21 M.N.Chickkanna Chettiar Trust, ACIT (Exemptions), 251, B.S. Sundaram Road, vs. Coimbatore.

Palayakkadu, Tiruppur – 641 601.

[PAN:AAATM-4901-C]

(अपीलाथ’/Appellant) (()यथ’/Respondent)

अपीलाथ’ क* ओर से/Appellant by : Shri. T.Banusekar, Advocate ()यथ’ क* ओर से/Respondent by : Ms. R. Kavitha, Addl. C.I.T.

सुनवाई क* तार(cid:9)ख/Date of Hearing : 09.09.2025 घोषणा क* तार(cid:9)ख/Date of Pronouncement : 15.10.2025 आदेश /O R D E R PER S. R. RAGHUNATHA, AM:

This appeal by the assessee is filed against the order of the Commissioner of Income Tax, Appeal, Addl./JCIT (A)-9, Mumbai, for the assessment year 2020-21, dated 26.03.2025.

2. The assessee has raised the following common grounds of appeal:-

1. For that the order of the Commissioner of Income Tax (Appeals) is contrary to law, facts, and circumstances of the case and is opposed to the principles of equity, natural justice and fair play.

2. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the order of the CPC, Bengaluru is without jurisdiction.

Legal Grounds

3. For that the Commissioner of Income Tax (Appeals) erred in dismissing the appellant’s case without providing the appellant a proper opportunity of being heard.

4. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the intimation issued u/s.143(1) of the Income Tax Act is bad in law.

5. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the intimation u/s.143(1) was passed without complying with the statutory requirement of law. Denial of exemption u/s.11

6. For that the Commissioner of Income Tax (Appeals) erred in upholding the intimation of the CPC, Bengaluru wherein the CPC, Bengaluru denied the exemption claimed by the appellant u/s.11.

7. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant had reasonable cause for non-filing of audit report in Form No. 10B within the prescribed due date.

8. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant is eligible to claim exemption u/s.11 in the facts and circumstances of the case.

9. For that, without prejudice to the above, the Commissioner of Income Tax (Appeals) erred upholding the intimation passed u/s.143(1) in bringing to tax the entire gross receipts of the appellant trust amounting to Rs.2,32,83,425/- without allowing expenditure incurred of Rs.1,64,47,483/- against the same.

10. For that without prejudice to the above, the Commissioner of Income Tax (Appeals) failed to appreciate that the tax liability at best could be computed only on the net income and not on the gross receipts ofRs.2,32,83,425/-.

11. For that, without prejudice to the above, the Commissioner of Income Tax (Appeals) failed to appreciate that the appellant trust ought to be taxed at slab rates and not at Maximum Marginal Rate.

Levy of interest u/s.234B and 234C

7. For that the appellant trust objects to the levy of interest under sections

234B and 234C of the Income Tax Act.

3. The brief facts of the case are that the assessee is a charitable trust registered u/s.12AA of the Income Tax Act, 1961 (in Short ‘the Act’) and filed its return of income for the A.Y. 2020-21on 03.02.2021. The return of income was processed u/s.143(1) on 30.11.2021 determining the total income of the assessee at Rs.2,32,84,425/-, whereby exemption u/s.11 was denied for the reason that audit report in Form No.10B was not filed within the due date prescribed under the Act read with rule 12A(1)(b), thereby assessing the entire gross receipts of Rs.2,32,84,425/- at maximum marginal rate without considering