https://www.taxtmi.com/caselaws?id=762334 ITAT SURAT-AT allowed the assessee's appeal against CIT(E)'s revision order u/s 263. The assessee, a trust, had not filed original return u/s 139 within due date but filed after receiving notice u/s 148. CIT(E) held AO's order erroneous for allowing exemption u/s 11 without timely filing. ITAT ruled that clause (ba) of section 12A(1) requiring timely filing was inserted by Finance Act 2017 effective from AY 2018-19 onwards, not applicable to AY 2017-18 in question. Since the mandatory filing provision didn't exist for the relevant assessment year, AO's order was neither erroneous nor prejudicial to revenue interests, making revision u/s 263 unjustified. en-us Wed, 27 Nov 2024 00:00:00 +0530 Thu, 28 Nov 2024 14:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762334 ITAT SURAT-AT allowed the assessee's appeal against CIT(E)'s revision order u/s 263. The assessee, a trust, had not filed original return u/s 139 within due date but filed after receiving notice u/s 148. CIT(E) held AO's order erroneous for allowing exemption u/s 11 without timely filing. ITAT ruled that clause (ba) of section 12A(1) requiring timely filing was inserted by Finance Act 2017 effective from AY 2018-19 onwards, not applicable to AY 2017-18 in question. Since the mandatory filing provision didn't exist for the relevant assessment year, AO's order was neither erroneous nor prejudicial to revenue interests, making revision u/s 263 unjustified. Case-Laws Income Tax Wed, 27 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762334