TaxTMI 
TaxTMI 
1978 (7) TMI 185
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.... under s. 11. The ITO brought the net profit as per profit and loss account to the extent of Rs. 15,870 to tax. 4. The assessee appealed to the AAC. By this time the assessee appeals for the earlier years were decided by the Tribunal and a revision application to the Commissioner was also disposed of. Based on this, the AAC held that the assessee was a charitable trust and it is entitled to exemption, but directed the ITO to look into s. 11(2) of the Act for purposes of giving effect to his order. On receipt of this order, the ITO amended the assessment on 14th Feb., 1974 holding that the total income was nil and cancelled the demand originally raised. On 20th Dec., 1974 the ITO passed a rectificatory order, whereby he amended his earlier ....
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....short time after 31st Dec., 1970 the assessee is eligible to get the exemption. Regarding the second year also he allowed the claim of the assessee to bad debts of Rs. 4,779 and held that the assessee had applied income by the payment of Rs. 30,000 on 2nd Jan., 1973 and a further sum of Rs. 6,000 on 6th Jan., 1973. In this manner he allowed the appeals of the assessee. 7. The revenue has come in appeal. The Departmental Representative submitted that there was no provision under s. 11 for consideration of failure to apply the opinion prescribed and the AAC's order should not have granted the exemption. The AAC's order should therefore, be reversed. In the second year, it was also submitted that the AAC was in error in allowing the claim for....