https://www.taxtmi.com/caselaws?id=428562 The fourth proviso to section 12A extends sections 11 and 12 only where assessment proceedings are actually pending on the date of registration and the charitable objects and activities remain unchanged; completed assessments for earlier years do not qualify, so the attempted extension of exemption was rejected. Reassessment under section 147 was upheld because the record did not show any prior specific examination of the sinking fund claim. However, 85% of development charges transferred to a sinking fund by a statutory urban development authority, being earmarked for mandated future public development expenditure and not freely available for appropriation, was not taxable income, and the related addition was deleted. en-us Fri, 30 Sep 2022 00:00:00 +0530 Tue, 04 Oct 2022 08:52:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428562 The fourth proviso to section 12A extends sections 11 and 12 only where assessment proceedings are actually pending on the date of registration and the charitable objects and activities remain unchanged; completed assessments for earlier years do not qualify, so the attempted extension of exemption was rejected. Reassessment under section 147 was upheld because the record did not show any prior specific examination of the sinking fund claim. However, 85% of development charges transferred to a sinking fund by a statutory urban development authority, being earmarked for mandated future public development expenditure and not freely available for appropriation, was not taxable income, and the related addition was deleted. Case-Laws Income Tax Fri, 30 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428562