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Revision u/s 263 - assessment of trust - donations given out of accumulated funds u/s. 11(2) of the Act of earlier previous years - The Tribunal noted the argument that the funds were disbursed only after ensuring they were used for construction purposes, aligning with the trust's objectives. - Upon careful consideration of the provisions of section 11(2) and section 11(3)(d) of the Act, the Tribunal concurred with the Ld. CIT (Exemption)'s finding that the donations made by the assessee from accumulated funds fell outside the permissible scope and were therefore taxable as income. The Tribunal upheld the decision that the assessment order lacked proper inquiry and verification by the AO, justifying the exercise of jurisdiction under section 263 of the Act.
Revision u/s 263 - assessment of trust - donations given out of accumulated funds u/s. 11(2) of the Act of earlier previous years - The Tribunal noted the argument that the funds were disbursed only after ensuring they were used for construction purposes, aligning with the trust's objectives. - Upon careful consideration of the provisions of section 11(2) and section 11(3)(d) of the Act, the Tribunal concurred with the Ld. CIT (Exemption)'s finding that the donations made by the assessee from accumulated funds fell outside the permissible scope and were therefore taxable as income. The Tribunal upheld the decision that the assessment order lacked proper inquiry and verification by the AO, justifying the exercise of jurisdiction under section 263 of the Act.
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