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ZAD Education Society Vs. CIT(E)

Case No: ITA No.440/Del/2021
Court: Income Tax Appellate Tribunal, Delhi Bench: ‘F’ New Delhi
Date: 3/19/2025

Parties Involved

AppellantZAD Education Society
RespondentCIT(E), Chandigarh

Facts Summary

The assessee, ZAD Education Society, filed an appeal against the Commissioner of Income Tax (Exemption) [CIT(E)], Chandigarh’s order dated 26.02.2021, which revised the regular assessment under section 263 of the Income-tax Act, 1961. The original assessment was conducted under section 143(2) on 30th June, 2017, focusing on the issue of a 'transaction to trust with specified person'. The CIT(E) sought to revise this assessment, alleging that the assessee lacked registration under section 12A, thus making it ineligible for section 11 exemption benefits. The assessee contested this revision, arguing that the Assessing Officer’s jurisdiction was limited to the specified issue and did not extend to other reasons.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the CIT(E) erred in revising the regular assessment on grounds beyond the scope of limited scrutiny.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

4 precedents cited in this judgement.

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ZAD Education Society Vs. CIT(E) | ITA No.440/Del/2021 | 2025 | Opakhya