ITA No. 2495/Bangalore/2025 Vishranthi Trust vs. Income Tax Officer, Exemptions

Parties Involved

Facts Summary

The assessee, Vishranthi Trust, a charitable trust based in Bengaluru, filed its return of income on 31 October 2017, declaring nil income after claiming exemption under sections 11 and 12 of the Income-tax Act, 1961. The return was selected for scrutiny, and a notice under section 143(2) of the Act was issued on 10 August 2018. During the assessment proceedings, the Assessing Officer sought details relating to donations of ₹20,030,712 received by the assessee. The assessee furnished donor details supporting donations of only ₹3,997,551 and failed to substantiate the remaining ₹16,033,161. Thus, the Assessing Officer treated ₹16,033,161 as anonymous donations and added that amount to the assessee’s income under section 115BBC of the Income-tax Act. Aggrieved by the assessment order, the assessee appealed to the Commissioner of Income Tax (Appeals). The CIT(A) partly allowed the assessee’s appeal, confirming the addition of ₹4,893,933 as anonymous donations because the assessee had not filed the mandatory application for admission of additional evidence.…

Legal Issues

• 1. Whether the action of the Assessing Officer in framing the impugned Assessment Order is bad in law and is opposed to the facts and circumstances of the case.
• 2. Whether the CIT(A) had erred in declining to admit the additional evidence on technical grounds.
• 3. Whether the CIT(A) had erred in confirming the addition of ₹4,893,933 as anonymous donations.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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