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    <title>2026 (1) TMI 186 - ITAT DELHI</title>
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    <description>Whether an assessee assessed as an AOP, being a charitable trust that surrendered its s.12A registration and did not claim exemption under s.11, was liable to tax at the maximum marginal rate with surcharge was the dominant issue. The Tribunal held that, although assessed as an AOP, the trust had no determinate members and its beneficiaries were the public at large; further, the conditions of CBDT Circular No. 320 dated 11-01-1982 stood satisfied, as already decided in the assessee&#039;s own case for the immediately preceding year. Consequently, tax was directed to be charged at the normal AOP slab rates, not at MMR with surcharge, and the appeal was allowed.</description>
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      <title>2026 (1) TMI 186 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784430</link>
      <description>Whether an assessee assessed as an AOP, being a charitable trust that surrendered its s.12A registration and did not claim exemption under s.11, was liable to tax at the maximum marginal rate with surcharge was the dominant issue. The Tribunal held that, although assessed as an AOP, the trust had no determinate members and its beneficiaries were the public at large; further, the conditions of CBDT Circular No. 320 dated 11-01-1982 stood satisfied, as already decided in the assessee&#039;s own case for the immediately preceding year. Consequently, tax was directed to be charged at the normal AOP slab rates, not at MMR with surcharge, and the appeal was allowed.</description>
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      <pubDate>Tue, 30 Dec 2025 00:00:00 +0530</pubDate>
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