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2018 (5) TMI 1310 - AT - Income TaxDisallowance u/s 11(2) - amount accumulated set apart for application to charitable or other purposes to the extent the said income did not exceed 15% of the income under Section 11(1)(a) - Held that:- All the details pertaining to the said claim of ₹ 98,57,10,000/- u/s 11(1)(a) and ₹ 10,21,26,000/- u/s 11(2) were duly mentioned in Form No. 10 B and Form No. 10 BB which is apparent from page no. 129 and 132 of the assessee’s paper book. In the present case, it is noticed the learned CIT(A) had not considered the contention raised by the assessee in right perspective and dismissed the appeal. Considering the totality of the facts deem it appropriate to remand this issue back to the file of the AO for adjudication in accordance with law, after proper verification from the material available on the record. We also direct to verify the amount of TDS which was claimed to be at ₹ 4,52,54,823/- while the amount considered was at ₹ 4,51,95,563/-. The AO shall provide a due and reasonable opportunity of being heard to the assessee.
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