Restored approval and continuing registration justified fresh adjudication of exemption denial and additions under reassessment.

Additions and denial of exemption under assessments framed under section 143(3) read with section 153A required fresh consideration because the approval under section 10(23)(c)(vi) had been restored and the assessee continued to hold registration under section 12AA. Applying judicial consistency with an earlier coordinate bench decision in similar restored-approval matters, the ITAT remanded the issues to the Assessing Officer for de novo adjudication. The assessee was permitted to raise all factual and legal pleas, including the consequential effect of the revived approval and continuing registration, and the appeals were allowed for statistical purposes.

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Issues: Whether the additions and denial of exemption made in the assessments framed under section 143(3) read with section 153A, in light of the restored approval under section 10(23)(c)(vi) and the continuing registration under section 12AA, required fresh consideration by the Assessing Officer.

Analysis: The assessments had been completed after withdrawing the approval under section 10(23)(c)(vi) and denying exemption under section 11. The approval was subsequently restored, and the assessees continued to hold registration under section 12AA. In view of the earlier coordinate bench decision restoring similar matters for fresh adjudication after revival of the approval, judicial consistency warranted the same course. The assessee was left at liberty to place all factual and legal pleas before the Assessing Officer, including the consequential effect of the restored approval and registration.

Conclusion: The matter was remanded to the Assessing Officer for fresh adjudication in accordance with law, and the appeals were allowed for statistical purposes.

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