The Court:-
1. The petitioner no. 1, in the instant case is a society registered
under the Society Registration Act, engaged in charitable activities. It has
filed Form 10A seeking registration under Section 12A(1)(ac)(iii) of the
Income Tax Act, 1961 (hereinafter referred to as the said Act) for the
Assessment Year 2022-23 to Assessment Year 2026-27. For Assessment
Year 2021-22, it filed a return declaring Nil income and claiming a refund
of Rs. 46,470/-.
2. In the instant case the return has been filed as ‘Nil’ return claiming
refund of Rs. 46,470/- but the Assessing Officer by an order passed under
Section 154 of the said Act has assessed income and raised demand,
being a high pitched assessment.
