High Court of Karnataka at Bengaluru · Judgments and reasoned final orders
The Commissioner of Income-Tax (Exemptions) & Anr. v. M/s. Anand Social and Education Trust
ITA No. 110 of 2022 c/w ITA No. 114 of 2022 ·
Following lead judgment in ITA No. 112/2022 (AY 2009-10), Revenue's appeals for AY 2011-12 challenging deletion of alleged unaccounted UG/PG/COMED-K fee additions dismissed.
1. FACTS OF THE CASE
The Revenue filed ITA No. 110 of 2022 and ITA No. 114 of 2022 under section 260A for AY 2011-12 challenging the common ITAT 'C' Bench order dated 29.05.2020 (in ITA No. 2657/Bang/2017 and ITA No. 2545/Bang/2017) which deleted search-assessment additions for alleged unaccounted UG, PG, and COMED-K cancellation seat fees.
2. DISCUSSION BY THE COURT
Applying its lead judgment of even date (29.07.2026) in ITA No. 112/2022 and connected matter for AY 2009-10, the Division Bench held that the same reasoning governed the appeals for AY 2011-12.
3. JUDICIAL DECISION
Substantial Questions of Law Nos. 1 and 2 in both appeals were answered in favour of the assessee and against the Revenue, Substantial Question of Law No. 3 was left open, and both appeals stood dismissed.
4. OUTCOME
In favour of the assessee (M/s. Anand Social and Education Trust); Questions 1 & 2 answered for assessee, Question 3 left open, and Revenue appeals dismissed.
5. AKHB REVIEW POINT
AKHB analysis: Uniform multi-year extrapolations across a 7-year section 153A block (AYs 2008-09 to 2014-15) based on uncorroborated loose sheets from two years cannot survive judicial scrutiny.
Source and verification
Reviewed from the complete 6-page official High Court judgment PDF (20260729_KAHC010120182021.pdf, SHA-256: 33f6e2b095663dfa085c8e373fe0b01abdae639a2b3ca98814eb7bbd911f6083).
Original PDF: 6 pages · SHA-256: 33f6e2b095663dfa085c8e373fe0b01abdae639a2b3ca98814eb7bbd911f6083
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Refers to the Income-tax Act, 1961 and allied statutory rules/circulars as applicable to the relevant assessment years.
No subsequent Supreme Court reversal or stay is recorded in the source judgment text.
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