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2014 (2) TMI 419 - ITAT AHMEDABADExemption u/s 11(1) of the Act – Interest income not shown in P&L account – Accumulation of income under Explanation-2 of section 11of the Act allowed – Held that:- There is no dispute that the mistake was committed while exercising option for allowing accumulation of income – assessee contended that such mistake is bona fide and the assessee cannot be deprived of legal claim on the basis of that the claim was not made within time, since the requirement of exercising option is directory in nature - CIT(A) ought to have considered the submissions of the assessee that the requirement of exercising option is being directory in nature, therefore a liberal approach to have been adopted – Relying upon Trustees Of Tulsidas Gopalji Charitable And Chaleshwar Temple Trust Versus Commissioner Of Income-Tax [1993 (9) TMI 75 - BOMBAY High Court] – the issue has been decided on wrong basis – Decided against Revenue and in favour of Assessee.
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