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Judgment
This assessee's appeal for assessment year 2019-20, arises against the Ld. Commissioner of Income Tax(Appeals)/National Faceless Appeal Centre,, New Delhi's, DIN & Order ITBA/NFAC/S/250/2025-26/1086560516(1) dated 26.02.2026 involving proceedings under section 143(3) of the Income- tax Act, 1961 (hereinafter referred to as 'the Act').
Heard both the parties. Case file perused.
For the reasons stated in the assessee's condonation averments, delay of 7 days in filing of the instant appeal is condoned in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).
It emerges at the outset that the assessee’s instant appeal hardly requires the tribunal to delve with the relevant factual matrix at length. This is for the precise reason that both the learned lower authorities have assessed its alleged anonymous donations of Rs.20,62,300/- u/s 115BBC of the Act for the sole reason that it had failed to plead and prove the relevant section 12A registration already granted in its case.
Learned departmental representative vehemently supports that the impugned addition that it was the assessee’s bounden duty to place on record that its section 12A registration before the learned lower authorities. He could hardly dispute that the same stood granted in assessee’s case on 27.17.2018 by the Ld. CIT(E), Delhi very much borne out from the case records at page 42 of the paper book. I thus see no reason to uphold the impugned section 115BBC addition which is hereby deleted in very terms.
The assessee’s appeal is allowed.