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The ITAT held that the disallowance under section 143(1) concerning application of funds was erroneous as the assessee had clearly disclosed the amount applied from previous years' accumulation in the return and audit report. The CIT(A)'s confirmation of the disallowance was factually incorrect and legally unsustainable. The Tribunal quashed the CIT(A) order and upheld the rectification made by the CPC, which accepted the return showing nil income. Consequently, the appeal was allowed, affirming the assessee's entitlement to exemption under section 11.
The ITAT held that the disallowance under section 143(1) concerning application of funds was erroneous as the assessee had clearly disclosed the amount applied from previous years' accumulation in the return and audit report. The CIT(A)'s confirmation of the disallowance was factually incorrect and legally unsustainable. The Tribunal quashed the CIT(A) order and upheld the rectification made by the CPC, which accepted the return showing nil income. Consequently, the appeal was allowed, affirming the assessee's entitlement to exemption under section 11.
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