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ITAT held that the AO exceeded statutory authority by denying exemption u/s 11 when the appellant held valid 12AA registration. The tribunal affirmed CIT(E)'s findings that once 12AA registration is granted, the AO cannot ignore such registration or probe further into trust's objectives. The question of applicability of section 2(15) remained academically unresolved, as the primary procedural issue favored the assessee. The decision effectively upheld the appellant's tax exemption status, rejecting revenue's contentions and maintaining the prior appellate order. Ultimately, the matter was decided against the revenue, preserving the appellant's tax-exempt standing.
ITAT held that the AO exceeded statutory authority by denying exemption u/s 11 when the appellant held valid 12AA registration. The tribunal affirmed CIT(E)'s findings that once 12AA registration is granted, the AO cannot ignore such registration or probe further into trust's objectives. The question of applicability of section 2(15) remained academically unresolved, as the primary procedural issue favored the assessee. The decision effectively upheld the appellant's tax exemption status, rejecting revenue's contentions and maintaining the prior appellate order. Ultimately, the matter was decided against the revenue, preserving the appellant's tax-exempt standing.
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