ITAT allowed most challenged deductions and restored charitable...

ITAT allowed most challenged deductions and restored charitable status of the assessee. Corpus donations were upheld as voluntary and genuine except donations from five unidentified donors (Rs.1.95 crore) remitted to AO for confirmation; related additions deleted. The assessee retained entitlement to accumulate up to 15% under section 11(1)(a) and prior non-filing of Form 9A did not preclude accumulation. The CIT(A)'s refusal to permit an unspecified accumulation under section 11(2) was sustained. Disallowance of fixed-asset costs and ad hoc expense disallowances were set aside and remitted to the AO for de novo adjudication and production of supporting evidence. Findings invoking sections 13(1)(c)/13(3) were reversed; exemption under sections 11, 12 and 13 restored and surplus additions deleted.

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