Chapter VI-A deduction for charitable trust restored; denial in processing treated as a rectifiable computational error.

A charitable trust that returned income as an association of persons and did not claim exemption under sections 11 and 12 could still seek deduction under Chapter VI-A, including sections 80G and 80GGA read with section 35AC, where the underlying donations were otherwise eligible. The denial of the deduction in processing under section 143(1) was treated as a computational mistake, and the error was held amenable to rectification under section 154. On that basis, the Assessing Officer was directed to allow the deduction and grant the consequential relief.

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Issues: Whether a charitable trust assessed as an association of persons, and not claiming exemption under sections 11 and 12, could claim deduction under Chapter VI-A, including sections 80G and 80GGA read with section 35AC, and whether the denial of such deduction in processing under section 143(1) could be corrected by rectification under section 154.

Analysis: The assessee was a charitable trust that had not claimed the benefits of sections 11 and 12 and had returned its income in the status of an AOP. The disallowance of the deduction claimed under Chapter VI-A was treated as a computational error, and the earlier refusal to grant relief was examined in light of the Tribunal's view in a similar case. The reasoning accepted that where the underlying donations were eligible and the claim had been made on the basis of the returned income, the denial of the deduction was not sustainable and the mistake was amenable to rectification.

Conclusion: The assessee was entitled to the deduction claimed under Chapter VI-A, including sections 80G and 80GGA read with section 35AC, and the Assessing Officer was directed to grant the benefit accordingly.

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