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ITAT allowed the appeal and directed the AO to admit exemption under s.11/12 for the appellant for AY 2018-19 on the basis of the first proviso to s.12A(2), holding that subsequent grant of registration u/s 12AA (during pending assessment) entitles the trust to s.11/12 benefits for the preceding year subject to verification and no change in objects/activities; the tribunal rejected the CIT(A)'s reasons, noting the proviso was operative for the relevant year, and remitted the matter to the AO to afford the appellant opportunity to furnish particulars and to compute and verify the admissible exemption (appeal allowed for statistical purposes).
ITAT allowed the appeal and directed the AO to admit exemption under s.11/12 for the appellant for AY 2018-19 on the basis of the first proviso to s.12A(2), holding that subsequent grant of registration u/s 12AA (during pending assessment) entitles the trust to s.11/12 benefits for the preceding year subject to verification and no change in objects/activities; the tribunal rejected the CIT(A)'s reasons, noting the proviso was operative for the relevant year, and remitted the matter to the AO to afford the appellant opportunity to furnish particulars and to compute and verify the admissible exemption (appeal allowed for statistical purposes).
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