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The ITAT allowed the appeal of the anonymized assessee, holding that the AO erred in applying the Maximum Marginal Rate with higher surcharge where the charitable trust/AOP had not sought exemption relief. The Tribunal found the appellant to be a registered charitable trust and a public body, rejecting the premise that beneficiaries were individual members whose shares warranted MMR treatment. The Tribunal further held that lower authorities misconstrued applicable law and were bound by the Board's clarificatory circular, precluding imposition of the flat maximum rate in these circumstances. The assessment under the MMR and enhanced surcharge was set aside and the appeal was allowed.
The ITAT allowed the appeal of the anonymized assessee, holding that the AO erred in applying the Maximum Marginal Rate with higher surcharge where the charitable trust/AOP had not sought exemption relief. The Tribunal found the appellant to be a registered charitable trust and a public body, rejecting the premise that beneficiaries were individual members whose shares warranted MMR treatment. The Tribunal further held that lower authorities misconstrued applicable law and were bound by the Board's clarificatory circular, precluding imposition of the flat maximum rate in these circumstances. The assessment under the MMR and enhanced surcharge was set aside and the appeal was allowed.
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