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2022 (11) TMI 6 - AT - Income TaxExemption u/s. 11 and 12 - assessee society is a case of general public utilities and, therefore, no longer enjoys charitable status - AO assessed the assessee as normal AOP - contention of the assessee did not find any favour with the AO who was of the firm belief that as per the amended provision of section 2 (15) - HELD THAT:- As mentioned elsewhere the impugned additions/ disallowances have been decided by this Tribunal in favour of the assessee in earlier assessment years. In so far as the applicability of section 2(15) of the Act is concerned this Tribunal in for A.Y.2009-10 [2019 (10) TMI 123 - ITAT DELHI] as decided AR supports the view taken by the Ld. CIT(A) on the aspect of principle of mutuality and the entitlement of the assessee to claim the benefit of Section 11 of the Act. We, therefore, uphold the same and find the grounds of appeal as devoid of merits. Quarrel relating to the decision of Global Development Activities expenses is concerned we find that the CIT(A) upheld the partial disallowance reducing the disallowance on the grounds that donations given by Government of India ought not to be disallowed - we decline to interfere with the findings of the CIT(A) the appeal filed by the revenue is accordingly dismissed.
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