Office of the Assistant Commissioner of Income Tax,

सहा. आयकर आयुक्त का कार्यालय,

Central Circle-3, Vadodara
सेंट्रल सर्कि ल-3, वडोदरा
6th floor, Room No.603, Aaykar Bhavan,
छठी मंजिल, कमरा नंबर 603, आयकर भवन,
Race Course Circle, Vadodara.
रेस कोर्स सर्क ल, वडोदरा।
Phone No. 0265-2312438,
e-mail: baroda.dcit.cen3@incometax.gov.in

No.VDR/ACIT/CC-3/C&S/148/SET/2023-24 Date: 27/03/2024

To
The Pr.Commissioner of Income-tax (Central)
Surat.

(Submitted through proper channel)

Respected Sir,

Sub: Request for prior approval as per provisions of section 148A(a) for
conducting inquiry before issuing show cause notice to assessee u/s 148A(b) of
the Income tax Act, 1961 in the case of Shital Education Trust (AAETS5713N)
A.Y 2020-21- reg.

Kindly refer to the subject above.

2. In this connection, it is respectfully submitted that information has been

flagged in CRIU/VRU for verification in Insight portal in the case of Bright School
Chandpur, Kakachiya, Lunawada, Panchmahal. This School is run by Shital
Education Trust. There are around 500 students studying in the school and out of
which around 300 Students are staying in the hostel of Bright School. The school fees
vary from class to class. The minimum fees starts from Rs. 6,500/- per annum for
students not availing the facility of hostel and the minimum fees for students availing
the facility of hostel is Rs. 45,000/- per annum. The assesse has filed its return of
income on 13/01/2021 at Rs. Nil.

3. On perusal of the Profit & Loss Account for the F.Y 2019-20 relevant to A.Y
2020-21 of the educational institutions run by the Shital Education Trust, it is seen
that the expenses regarding salary of Rs. 29,93,380/-, Rs. 34,22,960/-,RS.
27,63,677/- and Rs. 24,23,777/- totalling to Rs. 1,16,03,794/- in respect of Bright
day School, Bright Madhyamik Shala, Bright Primary School and Bright Hostel
respectively were claimed by the Shital Education Trust. But the Trust could not
furnish the list of employees (Teaching and non-teaching Staff) and salary paid to
them in spite of providing ample opportunities by the Investigating Wing, Godhra.

1
 The total expenses regarding payment of Salary of Rs. 1,16,03,794/- was
remains unexplained in the case of the assessee.
4. Looking to the above facts, the income chargeable to tax has escaped
assessment in the case of the assessee for the F.Y 2019-20 relevant to A.Y 2020-21.

5. The above constitutes information with the AO, which suggests income
chargeable to tax has escaped assessment in the case of the assessee, which falls in
the purview of the explanation -1(i) to section 148 of the IT Act.

6. As discussed above, further inquiry is required in the case to ascertain the

details. Details of the case is as under:
Sr.No. Name of the PAN A.Y Enquiry
assessee
1 Shital Education AAETS5713N 2020-21 Approval for calling of
Trust information u/s. 133(6) of
the Act from the assessee.

7. In view of above, it is requested to kindly accord approval for conducting inquiry

in above case u/s 148A(a) of the IT Act.

Submitted, for your kind perusal and necessary approval.

Yours faithfully,

(R.K Singh)
Asstt. Commissioner of Income-tax,
Central Circle-3, Vadodara.

2
 Proforma For approval under section 148A(a) of the Act
S.N. Requisite Parameters
1 Name of the assessee
2 PAN of the assessee
3 A.Y.
4 Information received from
5 Whether three years or less
have elapsed from the end of
relevant Assessment Year?
(Specified Authority as per
section 151 of the Act)
6 Gist of the Information (in one
sentence specify whether case
of Bogus loans/ unexplained
investment/ cash income etc.)
7 Line of Inquiry (Draft
Questionnaire)
Remarks
Shital Education Trust
AAETS5713N
2020-21
DDIT(Inv.), Godhra, flagged by Insight
portal.
No
The PCIT, Central Surat.
In this case, the assessee i.e Shital
Education Trust (PAN: AAETS5713N)
running School named Bright School an
amounting to Rs. 1,16,03,794/- may have
escaped the income for tax as the same
has been informed DDIT(Inv.),Godhra as
available in CRIU/VRU in Insight Portal.
Income chargeable to tax is represented in
the form of an expenditure in respect of a
transaction or in relation to an event or
occasion as per section 149(1)(b)(ii) of the
IT Act, 1961.
Calling of information u/s 133(6) from the
assessee for ascertaining whether it has
reflected in its books account and has the
income against it been offered for the
taxation in relevant AY 2020-21.
3
 ANNEXURE-A

DRAFT QUESTIONNAIRE TO ASSESSEE

To,
Shital Education Trust
Chandpur, Kakachiya,
Lunawada,
Panchmahal,
Gujarat 389230

Sir,
Sub: Calling for information u/s. 133(6) of the Income tax Act, 1961 in the
case of Shital Education Trust (PAN: AAETS5713N), A.Y. 2020-21 - reg.-

Please refer to the subject captioned above.

2. In this connection, it is noticed from ITBA System that the details in your case
which is related to expenses regarding payment of Salary of Rs. 1,16,03,794/- remains
unexplained.

3. In view of above, you are requested to show cause as to why a notice u/s.148 of
the income-tax Act,1961 should not be issued on the basis of information which
suggests that income exceeding Rs.50 Lac chargeable to tax has escaped assessment
in your case for the A.Y.2020-21.

4. As per information available with this office, it is observed that you have shown
Salary expenses of Rs.1,16,03,794/- in P&L Account during the F.Y 2019-20 relevant
to A.Y 2020-21. You are requested to kindly furnish the following details:

a) List of Staff Teaching and Non-Teaching

b) Bank statement wherein the payment of salary reflected
c) The documentary evidence in respect of expenses claimed at
Rs.1,16,03,794/-.

5. Your complete reply in this regard may be furnished latest by 15/04/2024

information is sought u/s. 133(6) of the 1. T. Act, 1961. Please note that failure to
comply with this notice may attract penal provisions u/s. 272A(2)(c) of the I. T. Act,
1961.
Yours faithfully,

(R.K Singh)
Asstt. Commissioner of Income-tax,
Central Circle-3, Vadodara.