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Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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When a registered charitable trust disclosed receipts under "income from other sources," denial of exemption was unwarranted because assessing authorities must apply a judicious approach and grant exemptions or deductions to which the assessee is entitled; appellate authorities are empowered and obligated to correct AO errors and may entertain reliefs not claimed in the return, with supporting precedents and administrative guidance cited. The failure of the AO, CIT(A) and Tribunal to consider merits resulted in reversal of the adverse outcome and payment of costs against the revenue, restoring the trust's entitlement to the claimed exemption.
When a registered charitable trust disclosed receipts under "income from other sources," denial of exemption was unwarranted because assessing authorities must apply a judicious approach and grant exemptions or deductions to which the assessee is entitled; appellate authorities are empowered and obligated to correct AO errors and may entertain reliefs not claimed in the return, with supporting precedents and administrative guidance cited. The failure of the AO, CIT(A) and Tribunal to consider merits resulted in reversal of the adverse outcome and payment of costs against the revenue, restoring the trust's entitlement to the claimed exemption.
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