Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
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Whether the assessee qualified as an Urban Local Body for exemption under section 10(20) was the primary issue; the Tribunal relied on subsequent assessment-year records showing the Revenue had dropped reassessment proceedings after recording that the assessee qualified as a local authority, treating those administrative actions and available materials as determinative. Applying that principle, the Tribunal held the assessee entitled to exemption and set aside additions made by the AO and affirmed by the CIT(A), deleting the assessed income for the relevant year and granting consequential relief to the assessee.
Whether the assessee qualified as an Urban Local Body for exemption under section 10(20) was the primary issue; the Tribunal relied on subsequent assessment-year records showing the Revenue had dropped reassessment proceedings after recording that the assessee qualified as a local authority, treating those administrative actions and available materials as determinative. Applying that principle, the Tribunal held the assessee entitled to exemption and set aside additions made by the AO and affirmed by the CIT(A), deleting the assessed income for the relevant year and granting consequential relief to the assessee.
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