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    <title>2025 (9) TMI 497 - ITAT BANGALORE</title>
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    <description>Exemption under sections 11 and 12 was unavailable for the relevant assessment years because the assessee did not hold valid registration under section 12A, 12AA or 12AB for those years. Registration in Form 10AC operated only from assessment year 2022-23, and the earlier years were outside its scope; the proviso extending benefit to earlier years did not apply because no assessment proceedings were pending when registration was granted. As a result, the nature of the collections as betterment fees or lake rejuvenation fees did not change their tax treatment, and the claim that they qualified as exempt receipts under section 11(1)(d) was rejected.</description>
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      <title>2025 (9) TMI 497 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=778008</link>
      <description>Exemption under sections 11 and 12 was unavailable for the relevant assessment years because the assessee did not hold valid registration under section 12A, 12AA or 12AB for those years. Registration in Form 10AC operated only from assessment year 2022-23, and the earlier years were outside its scope; the proviso extending benefit to earlier years did not apply because no assessment proceedings were pending when registration was granted. As a result, the nature of the collections as betterment fees or lake rejuvenation fees did not change their tax treatment, and the claim that they qualified as exempt receipts under section 11(1)(d) was rejected.</description>
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