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2016 (12) TMI 46 - ITAT BANGALORE

2016 (12) TMI 46 - ITAT BANGALORE - TMI - Denial of exemption u/ss. 11 & 12 as well as u/s. 10(23C) - status of society - Assessment framed in the status of AOP or AJP - aggregate annual receipts - Held that:- Clause (vi) makes it clear that if educational institution do not fall under either of those two categories and still such educational institutions are also entitled to the exemption, provided such institutions are approved by the prescribed authority. Therefore, all these three provisions .....

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rpose of section 10(23C) of the Act. - The assessee is a trust created vide trust deed dated 2.3.1995. There is no denial that the main object of the assessee trust is to impart education. The assessee is running two colleges in the name & style of M/s. Nargund College of Pharmacy and M/s. Nargund College of Physiotherapy. Besides this, the assessee is also running hostel meant for students. It is pertinent to note that upto FY 2003-04, the department accepted the assessee as charitable trus .....

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or the assessment purpose and not to after the real status of the trust. In the case of society, there is no special provision providing the status of the person in terms of section 2(31) of the Act and therefore it was held by the Hon'ble High Court in in the case of Children's Education Society [2013 (7) TMI 519 - KARNATAKA HIGH COURT ] that it would fall in the residual category of Artificial Juridical Person ["AJP"]. Whereas in case of income from property held under trust which is not eligi .....

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eopening of assessment - Held that:- It is undisputed fact that at the time of issuing notice u/s. 148, an application for registration was rejected by the DIT (E) and therefore as per the provisions of section 12A as existed at the relevant point of time, the AO has valid reason to believe that the income assessable to tax has escaped assessment. As regards the composite amount of receipts, it is only a matter of interpretation that for the purpose of section 10(23C) of the Act, the receipt of .....

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aving tangible material in the shape of rejection of registration as well as consolidated receipt of the assessee trust exceeding the exemption limit provided u/s. 10(23C) and hence initiation of proceedings u/s. 148 are valid. - Registration on expiry of six months from the date of application - Held that:- We find that the present proceedings are against the assessment order and not against the order of DIT (E) u/s. 12AA of the Act. Further, the issue of registration was earlier brought be .....

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NG.) OF 2012, AND CO. NOS. 80 TO 83 (BANG.) OF 2012 - Dated:- 30-9-2016 - VIJAY PAL RAO, JUDICIAL MEMBER, AND S. JAYARAMAN, ACCOUNTANT MEMBER C. Eranna, Jt. CIT (DR) for the Appellant. V. Chandrashekar, Adv. for the Respondent. ORDER 1. These appeals by the revenue and COs by the assessee are directed against the composite order of the CIT (Appeals) dated 12.1.2012 for the AYs 2004-05 to 2007-08. This is second round of hearing of the appeals and CO. The appeals and COs were disposed of by this .....

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ssed by the authorities below. We find that the contention of the assessee in respect of their status as Trust had not been considered by the Tribunal in proper perspective. We, however, do not wish to express any opinion on merits of the case, since learned counsel appearing for the parties have agreed for the order that we propose to pass. Learned counsel for the parties fairly stated that we need not record any further reasons for the following order: (i) The order dated 20th June 2013 render .....

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not expressed any opinion on merits of the case. We hope and trust that the Tribunal shall decide all the grounds of challenge raised by the parties in their appeals/Cross-Objections on merits in accordance with law." 2. Brief facts leading to the controversy involved in these cases are that the assessee is a trust established by way of trust deed executed on 2.3.1995 with the main objective of imparting education and to run the college of pharmacy and to run the college of physiotherapy in .....

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DIT (E) on 24.4.2009. 3. Against the said order dated 24.4.2009, the assessee filed appeal before the Tribunal and vide order dated 13.11.2009 the Tribunal set aside the matter to the file of DIT (E) for fresh consideration. The DIT (E) vide order dated 5.3.2010 granted registration u/s. 12A to the assessee trust w.e.f. 1.4.2008. 4. In the meantime, the AO issued a notice u/s. 148 on 30.12.2008 to reopen the assessment of four years under consideration. The AO completed assessments u/s. 143(3) .....

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on AOP is bad in law and therefore allowed the appeals in part. Thus, both the revenue as well as the assessee are aggrieved by the impugned order of CIT (A) and filed their respective appeals and COs. 6. The Revenue has raised the following grounds:- "(1) The order of the learned CIT (A) is opposed to the law and facts of the case. (2) The learned CIT (A) erred in holding that the assessments made on the assessee trust in the status of an 'Association of Persons' is bad in law and .....

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t appreciating that on denial of exemption U/s. 11 of the Income Tax Act, the charging section will be section 164(2) of the Act as per which the tax has to be charged at maximum marginal rate as the income so exempt were the income of the association of person. (5) Any other grounds which may arise at the time of hearing. (6) The order of the learned CIT (A) may be set-aside and the order of the A.O. may be confirmed." 7. In the CO, the assessee raised the grounds as under:- "1. The o .....

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lf liable to be assessed to tax as determined by the learned assessing officer of ₹ 34,90,364/- as against the income of Rs. NIL reported by the Respondent 1 Cross Objector under the facts and circumstances of the case. 4. Without Prejudice the learned Commissioner of Income- tax [Appeals] failed to appreciate that the Respondent/Cross Objector had made an application before the learned DIT for the recognition under section 12A of the Act the learned DIT failed to dispose of the applicatio .....

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e Act the gross receipts of each institution to be considered separately for the purpose of allowing the claim of exemption under section 10(23c)(iiiad) of the Act under the facts and circumstances of the case. 6. The Respondent/Cross Objector craves leave to add, alter, delete or substitute any of the grounds urged above. 7. In view of the above and other grounds that may be urged at the time of hearing of the Cross Objection, your Respondent/Cross Objector humbly pray that the Cross Objection .....

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ns of section 164(2) of the act, the income derived from the property held under trust wholly for charitable or religious purpose are not exempt u/s. 11 or 12 of the Act, shall be chargeable to tax as it were the income of the AOP. Thus, the ld. DR submitted that the CIT (Appeals) has committed an error while holding that the assessment order framed in the status of AOP is bad in law. The ld. DR has contended that when there is a special provision u/s. 164(2) that an income which is not exempt u .....

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r, when the registration u/s. 12A was granted w.e.f. 1.4.2008, then the benefit of sections 11 and 12 ought to have been given to the assessee as per the first proviso to section 12A(2) of the Act. He has further submitted that the application filed on 14.3.2005 was not acted upon by the DIT (E) and therefore upon the expiry of six months from the date of filing, it would be deemed registration and consequently exemption ought to have been given u/s. 11 & 12 of the Act. In support of his con .....

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the purpose of section 10(23C) of the Act whereas each education institution is a separate organisation for the purpose of this section and therefore the turnover of each educational institution/college is required to be considered separately for the purpose of section 10(23C)(ii)(d). He has pointed out that the assessee trust is running two institutions viz., Nargund College of Pharmacy and Nargund College of Physiotherapy, but the receipts of each college has to be considered separately for th .....

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e jurisdictional High Court in the case of CIT v. Children's Education Society [2013] 358 ITR 373 (Kar.). Thus, it was contended that the AO was not justified in assessing the entire receipt of tax and changing the status of assessee from trust to AOP. He has forcefully contended that even non-grant of registration u/s. 12A of the Act would not alter the status of assessee being charitable trust. 11. In the rejoinder, the ld. DR has submitted that the first proviso to section 12A(2) of the A .....

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becomes infructuous. In any case, the assessee has filed a fresh application on 21.10.2008 without praying for adjudication of the alleged earlier application filed on 14.3.05. He has relied upon the decision of the Hon'ble Madras High Court in the case of CIT v. Sheela Christian Charitable Trust 2013 (3) TMI 268 - MADRAS HIGH COURT and submitted that the Hon'ble High Court has held that the time frame u/s. 12AA of the Act is only directory and not passing the order within six months wo .....

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tcome of the main issue of assessability of receipts of the assessee and benefit of deduction u/s. 11 of the I.T. Act. At this stage, it is pertinent to discuss and analyse the relevant facts and development occurred during the entire process of grant of registration u/s. 12A of the Act. 15. The assessee is a trust created vide trust deed dated 2.3.1995. There is no denial that the main object of the assessee trust is to impart education. The assessee is running two colleges in the name & st .....

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ssessee has applied for grant of Registration U/S. 12A of the Income Tax Act, 1961 on 26.08.2004. The Trust was established on 02.03.1995. On processing the application, deficiency letter was issued on 2.11.2004 calling for details of books of account for the year ending 31.3.2004. The case was posted for hearing on 24.11.2004. Sri S.M. Mattikalli, Chartered Accountant, Authorised Representative of the assessee appeared and discussed the case. On perusing the details, he was asked to file additi .....

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cation of funds. 2. In the interest of natural justice, final opportunity was given vide show cause notice dtd. 13.1.2005 posting the case for bearing on 21.1.2005. None appeared for hearing and no details have been filed. 3. In the circumstances, there is no option but to reject the assessee's application for grant of Registration u/s. 12A of the Income Tax Act, 1961, for non-compliance. 4. Accordingly, the assessee's application u/s. 12A of the Income Tax Act, 1961 is rejected." 1 .....

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a considerable period and therefore assessee filed third application dated 21.10.2008 which was rejected on merits vide order dated 24.4.09. However, the matter was remanded back by this Tribunal to DIT (E) and subsequently registration was granted vide order dated 5.3.10 w.e.f. 1.4.2008. It is apparent from the record that the AO issued notice u/s. 148 on 30.12.08 primarily on the ground that the assessee has not been registered u/s. 12A of the Act, whereas registration was finally granted w.e. .....

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ed asst. within the meaning of section 147 of the Act. Hence, this is a fit case for issue of notice u/s. 148 of the Act." 18. The AO proposed to initiate proceedings u/s. 148 on the reasons that the assessee is neither registered u/s. 12A of the Act nor got notified u/s. 10(34C) of the Act, as the gross receipt exceeds Rs. Two crore. The assessment orders were passed u/s. 143(3) r.w.s. 147 based on two premises as understood by the AO that neither registration u/s. 12A was granted nor exem .....

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of proceedings u/s. 148 of the Act. Therefore, the entire basis of the assessment order was no more in existence, after the grant of registration u/s. 12A. 19. At this stage, we quote the proviso to section 12A as under:- "Provided that where an application for registration of the trust or institution is made after the expiry of the period aforesaid, the provisions of sections 11 and 12 shall apply in relation to the income of such trust or institution,- (i) from the date of the creation o .....

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ted under this Act without giving effect to the provisions of section 11 and section 12 exceeds fifty thousand in any previous year, the accounts of the trust or institution for that year have been audited by an accountant as defined in the Explanation below sub-section (2) of section 288 and the person in receipt of the income furnishes along with the return of income for the relevant assessment year the report of such audit in the prescribed form duly signed and verified by such accountant and .....

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e of trusts or institutions which apply for registration after 1st June, 2007, the registration shall be effective only prospectively. 8.2 Non-application of registration for the period prior to the year of registration caused genuine hardship to charitable organisations. Due to absence of registration, tax liability is fastened even though they may otherwise be eligible for exemption and fulfil other substantive conditions. However, the power of condonation of delay in seeking registration was .....

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sessing Officer as on the date of such registration, if the objects and activities of such trust or institution in the relevant earlier assessment year are the same as those on the basis of which such registration has been granted. 8.4 Further, it has been provided that no action for reopening of an assessment under section 147 of the Income-tax Act shall be taken by the Assessing Officer in the case of such trust or institution for any assessment year preceding the first assessment year for whi .....

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1. This object of amendment to insert the proviso to section 12A is to remove the genuine hardship caused by the earlier amendment whereby the powers of the competent authority to condone the delay in applying the registration was taken away and consequently due to time gap in registration, tax liability is fastened. Thus, the nature and purpose of amendment is to supply the obvious omission in the existing provisions as well as to provide the benefit to the genuine assessees without inflicting .....

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te prior to the financial year of application. Further in the case of assessee, there is no allegation of change of objects or activities as it was at the time of granting registration in comparison to the objects of activity during the years under consideration. 22. Thus, benefit of sections 11 and 12 of the Act cannot be denied merely on the ground that registration is granted w.e.f. 1.4.2008, though by a subsequent order, but the registration u/s. 12A came into effect prior to the initiation .....

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der the Rules. In other words, if the aggregate annual receipts of an educational institution is less than one crore, the income from such educational institution in the hands of the assessee, is not taken into consideration in computing the total income of the assessee. 19. Sub-clause (vi) provides that any university or other educational institution existing for educational purpose and not for the purpose of profit other than those mentioned in sub-clause (iiiab) and sub-clause (iiiad) and whi .....

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ther educational institutions means the aggregate of annual receipts of all such educational institutions put together. Otherwise, the use of the word "aggregate" loses its meaning. We find it difficult to accept the said argument. 21. Firstly, if the word "aggregate annual receipts" of other educational institution is to be understood as clubbing of annual receipts of all educational institutions run by an assessee-society, then it will also include the annual receipts of an .....

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iiab), the income on behalf of such educational institution received by the assessee is exempted from being computed the total income of the assessee. If the assessee is running other educational institutions which are not wholly or substantially financed by the Government, then the benefit of that exemption is also extended to the income derived from such educational institutions and received by the assessee under sub-clause (iiiad) reading with sub-clause (iiiad) along with rule 2BC. It was co .....

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der to form a whole." 22. Similarly, relying on the judgment of the apex court in the case of Aditanar Educational Institution v. Addl. CIT, it was contended the words "other educational institution" refers to the assessee society and not to the individual educational institution. If the intention of the Legislature was to club the annual receipts of all educational institutions run by the assessee society, they could have said so in clear terms. On contrary what is stated in the .....

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quot;other educational institution" has to be understood in the context of other than any university. If so understood, all that it means is every educational institution existing solely for educational purpose and not for the purpose of profit, if the aggregate annual receipts of such educational institution exceeds ₹ 1 crore, then the income from such educational institution received by the assessee is excluded from his total income. In an educational institution the amount are calc .....

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e taken into consideration to compute the income of the assessee. 23. No doubt, education has become a business, a very profitable business also. But it requires huge investment. It is the duty of the Government to provide education to all its citizens, as the Government is not able to shoulder the responsibility completely. Therefore, the field of education is now thrown open to private organizations. But for throwing open the field to the private operators, probably, the country would not have .....

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these educational institutions would be in the hands of the societies or the trust, but for all other purposes they are different, independent entities. That is the reason why section 10(23C) is worded as under: "any income received by any person on behalf of. . . . " 24. Here "any person" refers to the assessee and "on behalf of" refers to such institutions. It may be an university, it may be an educational institution, it may be a hospital or other institutions of .....

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at ₹ 1 crore. Therefore, irrespective of the expenditure incurred by those institutions, the exemption is based on the total receipts. Even if the word "aggregate" has to be understood as suggested by the Revenue as the annual receipts of such educational institutions put together, probably, the said provision regarding exemption would be of no use at all. Especially, if the society is running a medical college or any engineering college or other professional courses, then the an .....

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Government, then the income from such educational institution received by the assessee is not included while computing his total income. Similarly, income from each educational institution if they are not receiving any aid from the Government wholly or substantially in respect of which the aggregate annual receipt do not exceed ₹ 1 crore received by the assessee, is also not included while computing annual total income of the assessee. 25. Clause (vi) makes it clear that if educational ins .....

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s, total annual receipt of each educational institution, is correct and it does not call for any interference. Therefore, the substantial questions of law Nos. 2 and 3 is answered in favour of the assessee and against the Revenue.' 24. Respectfully following the judgment of the Hon'ble jurisdictional High Court (supra), we hold that the annual receipt of each college which is a separate educational institution, has to be considered for the purpose of section 10(23C) of the Act. 25. Thoug .....

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ual, (ii) a Hindu undivided family, (iii) a company, (iv) a firm, (v) an association of persons or a body of individuals, whether incorporated or not, (vi) a local authority, and (vii) every artificial juridical person, not falling within any of the preceding sub-clauses. Explanation. - For the purposes of this clause, an association of persons or a body of individuals or a local authority or an artificial juridical person shall be deemed to be a person, whether or not such person or body or aut .....

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e Societies Registration Act, 1860, any seven or more persons associated for any literary, scientific or charitable purpose, may by subscribing their names, to a memorandum of association and filing the same with the Registrar of Societies may form themselves into a Society under the Act. 8. Once the society is formed, it would become a juridical person as opposed to natural persons. Business of the society is carried on in the name of the society and not in the name of the persons who form the .....

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than the association of persons or body of individuals. Therefore, the society while filing return is described the status as artificial juridical person. The assessing authority could not accept the said status and treated the assessee as an association of persons and has passed the order. Now, the Tribunal has held that the assessee is to be treated as artificial juridical person. When the return is filed as artificial juridical person, the question of treating the assessee as an association .....

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s, or which is of the nature referred to in sub-clause (iia) of clause (24) of section 2, or which is of the nature referred to in sub-section (4A) of section 11, tax shall be charged on so much of the relevant income as is not exempt under section 11 or section 12, as if the relevant income not so exempt were the income of an association of persons: Provided that in a case where the whole or any part of the relevant income is not exempt under section 11 or section 12 by virtue of the provisions .....

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would fall in the residual category of Artificial Juridical Person ["AJP"]. Whereas in case of income from property held under trust which is not eligible for exemption u/ss. 11 and 12 of the Act, it will be dealt with as per the special provisions of section 164(2) of the Act, which stipulates the status in which the income is assessable. Therefore, this provision is applicable only when the income is found to be not eligible for exemption u/ss. 11 and 12 of the Act. In the case in ha .....

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n nature and does not require any specific adjudication. 30. Ground No. 2 is regarding validity of order passed u/s. 143(3) r.w.s. 147 of the Act for want of jurisdiction u/s. 148. The ld. AR of assessee has submitted that non-filing of return would not give jurisdiction to the AO automatically to initiate proceedings u/s. 148, when the assessee was not having any taxable income and therefore as per provisions of section 139(4A), it was not required to file a return of income. Further, all recei .....

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ion of facts and took the consolidated receipts of both the educational institutions instead of receipts of each college separately for the purpose of exemption u/s. 10(23C) of the Act. Therefore, there is no material or new information available with the AO to form a belief that income assessable to tax has escaped assessment. 31. On the other hand, the ld. DR has submitted that at the time of issuing notice u/s. 148, proviso to section 12A as relied upon by the assessee was not in the statute .....

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. 148 is a prima facie reasonable belief that assessee is not eligible for exemption u/s. 10(23C) because the gross amount of receipts are more than the prescribed limit. He has relied upon the orders of authorities below. 32. We have considered the rival submissions as well as relevant material on record. It is undisputed fact that at the time of issuing notice u/s. 148, an application for registration was rejected by the DIT (E) and therefore as per the provisions of section 12A as existed at .....

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notice was issued by the AO u/s. 148, the AO was justified to believe that consolidated amount of receipts of the assessee trust are to be taken into account for the purpose of exemption u/s. 10(23C) of the Act. Therefore, at the stage of forming the belief, the AO was having tangible material in the shape of rejection of registration as well as consolidated receipt of the assessee trust exceeding the exemption limit provided u/s. 10(23C) and hence initiation of proceedings u/s. 148 are valid. 3 .....

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s as well as relevant material on record, we find that the present proceedings are against the assessment order and not against the order of DIT (E) u/s. 12AA of the Act. Further, the issue of registration was earlier brought before the Tribunal and in the set aside proceedings, the DIT (E) granted registration vide order dated 5.3.2010 w.e.f. 1.4.2008. The said order has not been challenged by the assessee, therefore, the issue of registration has attained finality and cannot be agitated in the .....

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ss Objector are opposed to law, weight of evidence, natural justice, facts and circumstances of the case. 2. Without prejudice the order passed by the learned Assistant Deputy of Income-tax [Exemptions] under section 143[3] r.w.s. 147 of the Act is without jurisdiction, since the status of the Respondent/Cross Objector was not recognized as Trust and the learned assessing officer ought to have transferred the case of the Respondent/Cross Objector to the respective ward in which the jurisdiction .....

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idered the relevant record on the point of admission of additional ground. Since it is a pure question of law and does not require any investigation of facts, therefore in view of the decision of the Hon'ble Supreme Court in the case of NTPC Ltd. v. CIT [1998] 229 ITR 383, the additional ground raised by the assessee is admitted for adjudication. 39. The ld. AR for the assessee has submitted that when the AO has not recognized the assessee as trust and framing the assessment by treating the .....

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