Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
ITAT allowed the assessee's appeal and set aside the denial of exemption u/s 11 and 12 made in intimation u/s 143(1)(a) and confirmed by CIT(A). It held that the assessee had a valid and subsisting registration u/s 12A during the relevant previous year and that subsequent registration u/s 12AB, granted from AY 2022-23, did not extinguish or interrupt the earlier registration. The Tribunal held that the transition from sections 12A/12AA to 12AB is non-disruptive and the proviso to section 12A(2) protects exemption during the intervening period. Mere non-filling of the new registration number in the ITR could not justify denial of exemption.
ITAT allowed the assessee's appeal and set aside the denial of exemption u/s 11 and 12 made in intimation u/s 143(1)(a) and confirmed by CIT(A). It held that the assessee had a valid and subsisting registration u/s 12A during the relevant previous year and that subsequent registration u/s 12AB, granted from AY 2022-23, did not extinguish or interrupt the earlier registration. The Tribunal held that the transition from sections 12A/12AA to 12AB is non-disruptive and the proviso to section 12A(2) protects exemption during the intervening period. Mere non-filling of the new registration number in the ITR could not justify denial of exemption.
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