ITAT allowed the appeal for statistical purposes and remanded...

ITAT allowed the appeal for statistical purposes and remanded the matter to CIT(A) for factual verification. The assessee society claimed exemption u/s 11(1)(d), which was denied through intimation u/s 143(1) treating government scheme funds as "income" u/s 2(24). ITAT held that if the society operates as a simpliciter pass-through entity under "Rashtriya Gokul Mission" without control over funds or right to retain unutilized amounts, such funds cannot constitute "income" u/s 2(24). The tribunal directed CIT(A) to verify the factual position regarding the society's role as implementing agency and whether AO/CPC Bengaluru complied with statutory obligations under provisos to Section 143(1) regarding notice and objections before making adjustments.

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