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ITAT ruled invalid reopening of assessment for a religious and charitable trust regarding anonymous Hundi/charity box collections under s.115BBC. AO's belief based on legal interpretation rather than tangible material was insufficient grounds for reopening. Trust's religious-charitable status exempted it from s.115BBC(2) taxation of anonymous donations. ITAT upheld deductions under s.11(1)(a) on gross receipts following SC precedent, and allowed enhanced s.11(2) claims despite Form No.10 deficiencies, citing Gujarat HC's ruling that technical inaccuracies aren't fatal to charitable deduction claims. Resolution specified purposes and earmarked amounts satisfied statutory requirements. Appeal allowed in taxpayer's favor.
ITAT ruled invalid reopening of assessment for a religious and charitable trust regarding anonymous Hundi/charity box collections under s.115BBC. AO's belief based on legal interpretation rather than tangible material was insufficient grounds for reopening. Trust's religious-charitable status exempted it from s.115BBC(2) taxation of anonymous donations. ITAT upheld deductions under s.11(1)(a) on gross receipts following SC precedent, and allowed enhanced s.11(2) claims despite Form No.10 deficiencies, citing Gujarat HC's ruling that technical inaccuracies aren't fatal to charitable deduction claims. Resolution specified purposes and earmarked amounts satisfied statutory requirements. Appeal allowed in taxpayer's favor.
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