https://www.taxtmi.com/caselaws?id=448733 The ITAT Delhi restored an appeal to CIT(A) regarding taxability of unutilized accumulated funds under section 11(2) as income under section 11(3). The AO had reframed assessment following section 263 order, holding the assessee ineligible for exemption under sections 11/12 based on mutuality principles. CIT(A) initially dismissed the appeal stating DIT(E) directions had attained finality. However, following Delhi HC directions to consider substantive merits regarding section 11(3) taxability, ITAT remanded the matter to CIT(A) for fresh consideration of the claim under sections 11(2) and 11(3) provisions with adequate hearing opportunity. en-us Wed, 03 Jan 2024 00:00:00 +0530 Sun, 28 Jan 2024 11:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448733 The ITAT Delhi restored an appeal to CIT(A) regarding taxability of unutilized accumulated funds under section 11(2) as income under section 11(3). The AO had reframed assessment following section 263 order, holding the assessee ineligible for exemption under sections 11/12 based on mutuality principles. CIT(A) initially dismissed the appeal stating DIT(E) directions had attained finality. However, following Delhi HC directions to consider substantive merits regarding section 11(3) taxability, ITAT remanded the matter to CIT(A) for fresh consideration of the claim under sections 11(2) and 11(3) provisions with adequate hearing opportunity. Case-Laws Income Tax Wed, 03 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448733