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    <title>2024 (4) TMI 835 - ITAT CHENNAI</title>
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    <description>ITAT Chennai held that reopening of assessments for AYs 2012-13 to 2014-15 was invalid due to lack of allegation regarding non-disclosure of material facts, while reopening for AYs 2015-16 to 2016-17 was valid based on fresh tangible material from survey. The trust was granted exemption u/s 11 as running Kalyanamandapam was incidental to main charitable objects and covered under Sec 11(4). No addition was made for rental income difference as adequate consideration was paid at prevailing market rates, thus Sec 13(1)(c) was inapplicable. Depreciation on fixed assets was allowed as application of income up to AY 2014-15 but disallowed from AY 2015-16 onwards due to amended Sec 11(6) provisions.</description>
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      <link>https://www.taxtmi.com/caselaws?id=751654</link>
      <description>ITAT Chennai held that reopening of assessments for AYs 2012-13 to 2014-15 was invalid due to lack of allegation regarding non-disclosure of material facts, while reopening for AYs 2015-16 to 2016-17 was valid based on fresh tangible material from survey. The trust was granted exemption u/s 11 as running Kalyanamandapam was incidental to main charitable objects and covered under Sec 11(4). No addition was made for rental income difference as adequate consideration was paid at prevailing market rates, thus Sec 13(1)(c) was inapplicable. Depreciation on fixed assets was allowed as application of income up to AY 2014-15 but disallowed from AY 2015-16 onwards due to amended Sec 11(6) provisions.</description>
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