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2022 (8) TMI 583 - AT - Income TaxRectification u/s 154 - Entitlement to exemption u/s 11 - expenses so claimed fully entitled to get which made for public charitable purpose according to the provisions of the Act - trust has filed an application for registration u/s 12AA of Income Tax Act, 1961 and ld. Commissioner of Income Tax (Exemption), Jaipur granted registration certificate under section 12AA - HELD THAT:- As looking into the entirety of facts and circumstances that the assessee trust is registered under section 12AA w.e.f. 11.07.1966 and continuously getting benefit of section 11 of the IT Act, however, because of change in the system of the Department all the cases were transferred to New Ward (Exemption), therefore, technically the assessee trust again applied registration which was granted vide order dated 06.05.2016. Even the department while considering the entire facts of the case had already allowed expenses under section 11 of the Act for the assessment years 2012-13, 13-14 and 14-15. Therefore, keeping in view the principles of natural justice and consistency, we direct the AO to give benefit of section 11 to the assessee for the year under consideration. The order of ld. CIT (A) is set aside - Appeal of the assessee is allowed.
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