https://www.taxtmi.com/caselaws?id=761783 ITAT Hyderabad set aside CIT(A)'s order denying section 11 exemption to trust for failure to e-file Form 10BB audit report within prescribed time. Trust's delay exceeded 365 days but argued COVID period should be excluded. ITAT found ambiguity in CBDT Circular 15/2022 regarding condonation authority for delays beyond 3 years. Matter remanded to AO for fresh consideration pending CBDT's decision on trust's condonation application. ITAT also directed that if exemption ultimately denied, trust should be assessed as AOP on surplus/profit only, not gross receipts. en-us Thu, 14 Nov 2024 00:00:00 +0530 Sat, 16 Nov 2024 08:38:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761783 ITAT Hyderabad set aside CIT(A)'s order denying section 11 exemption to trust for failure to e-file Form 10BB audit report within prescribed time. Trust's delay exceeded 365 days but argued COVID period should be excluded. ITAT found ambiguity in CBDT Circular 15/2022 regarding condonation authority for delays beyond 3 years. Matter remanded to AO for fresh consideration pending CBDT's decision on trust's condonation application. ITAT also directed that if exemption ultimately denied, trust should be assessed as AOP on surplus/profit only, not gross receipts. Case-Laws Income Tax Thu, 14 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761783