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The ITAT held that the denial of exemption u/s 11 to Assessee Trust A, already registered u/s 12A, on the sole ground of belated filing of Form 10B was unsustainable. The Tribunal noted that the return was filed within the extended statutory time u/s 139(4) pursuant to an Order u/s 119(2)(a), and the audit report in Form 10B, though delayed, was subsequently filed. Such delay was treated as a procedural irregularity amounting to substantial compliance with s.12A(1)(b), not warranting forfeiture of exemption. Emphasizing liberal interpretation of beneficial provisions for charitable entities, the ITAT held the CPC was not justified in taxing gross receipts and allowed the assessee's appeal.
The ITAT held that the denial of exemption u/s 11 to Assessee Trust A, already registered u/s 12A, on the sole ground of belated filing of Form 10B was unsustainable. The Tribunal noted that the return was filed within the extended statutory time u/s 139(4) pursuant to an Order u/s 119(2)(a), and the audit report in Form 10B, though delayed, was subsequently filed. Such delay was treated as a procedural irregularity amounting to substantial compliance with s.12A(1)(b), not warranting forfeiture of exemption. Emphasizing liberal interpretation of beneficial provisions for charitable entities, the ITAT held the CPC was not justified in taxing gross receipts and allowed the assessee's appeal.
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