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2022 (6) TMI 267 - AT - Income TaxRectification of mistake u/s 154 - denial of exemption u/s 11 - Taxability of corpus donations when exemption u/s.11 is denied is a debatable issue which cannot be entertained u/s. 154 - whether corpus donation has to be taxed or totally exempt at the stage of rectification under section 154 after attaining finality before the final facts finding authority? - HELD THAT:- We find that the rectification petition filed by the assessee under section 154 of the Act is a debatable issue and therefore, it cannot be considered at this stage. That apart, the ld. Counsel for the assessee has submitted that the issue is pending before the Hon’ble High Court. Under the above facts and circumstances, we find no infirmity in the order passed by the ld. CIT(A) and accordingly, the appeal filed by the assessee is dismissed.
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