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ITAT allowed the assessee-trust's appeal regarding revision under section 263 and exemption eligibility under section 11. The CIT had directed the AO to conduct inquiries into interest transactions and verify activities against trust objects. ITAT held that micro-financing activities to poor rural women constitute charitable activities under the first limb of section 2(15), qualifying for section 11 exemption. The decision relied on the principle of consistency, noting that ITAT Cochin Bench previously held identical micro-financing activities as charitable for AY 2011-2012, confirmed by Kerala HC. Despite res judicata not applying to income tax proceedings, consistency principle applies when identical facts permeate across assessment years. The trust's rural micro-financing qualified as relief to the poor rather than general public utility activities.
ITAT allowed the assessee-trust's appeal regarding revision under section 263 and exemption eligibility under section 11. The CIT had directed the AO to conduct inquiries into interest transactions and verify activities against trust objects. ITAT held that micro-financing activities to poor rural women constitute charitable activities under the first limb of section 2(15), qualifying for section 11 exemption. The decision relied on the principle of consistency, noting that ITAT Cochin Bench previously held identical micro-financing activities as charitable for AY 2011-2012, confirmed by Kerala HC. Despite res judicata not applying to income tax proceedings, consistency principle applies when identical facts permeate across assessment years. The trust's rural micro-financing qualified as relief to the poor rather than general public utility activities.
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