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HC held that the reassessment proceedings initiated against the Petitioner-trust were invalid and liable to be quashed. It was found that the Petitioner had duly complied with s.11(2) of the Act by filing Form 10 electronically, specifically indicating the purposes of accumulation through a referenced Resolution, which was also on record. HC held that limited space in Form 10 justified referring to the Resolution, and such reference satisfied the statutory requirement read with r.17. The reasons recorded by the AO alleging non-compliance with s.11(2) were held to be erroneous and irrelevant, particularly since the Resolution was available on the portal and considered part of the record. Having fulfilled s.11(2), the Petitioner was entitled as of right to exemption, and the reassessment was set aside.
HC held that the reassessment proceedings initiated against the Petitioner-trust were invalid and liable to be quashed. It was found that the Petitioner had duly complied with s.11(2) of the Act by filing Form 10 electronically, specifically indicating the purposes of accumulation through a referenced Resolution, which was also on record. HC held that limited space in Form 10 justified referring to the Resolution, and such reference satisfied the statutory requirement read with r.17. The reasons recorded by the AO alleging non-compliance with s.11(2) were held to be erroneous and irrelevant, particularly since the Resolution was available on the portal and considered part of the record. Having fulfilled s.11(2), the Petitioner was entitled as of right to exemption, and the reassessment was set aside.
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