2020 (5) TMI 404

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....ent appeal has been preferred by the assessee against the order dated 31.01. 2017 of the Commissioner of Income Tax (Appeals), Palampur [hereinafter referred to as 'CIT(A)']. 2. The assessee in this appeal has taken following grounds of appeal:- 1. That the order of Ld. CIT(A) is against the law and facts of the case. 2. That the Ld. CIT(A) and Ld. Assessing Officer both have erred by not all....

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....ssee has been granted registration u/s 12A of the Income Tax Act, 1961 ( in short 'the Act') for assessment year 2011- 12 on 11.9. 2010, whereas, the assessment year involved in the present appeal is assessment year 2010-11. That assessment order in this case has been passed on 24. 12. 2012 i. e. after the grant of registration in the subsequent year by the assessee on 19. 11. 2020. The as....

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....y in respect of any income derived from property held under trust of any assessment year preceding the aforesaid assessment year, for which assessment proceedings are pending before the Assessing Officer as on the date of such registration and the objects and activities of such trust or institution remain the same for such preceding assessment year: Provided further that no action under section ....

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....o the condition of the assessment of such preceding year is pending before the Assessing Officer on the date of such registration. The Ld. counsel, therefore, has submitted that as per the aforesaid proviso that since the assessment for the year under consideration was pending before the Assessing Officer, hence, the assessee is entitled to deduction as per provisions of sections 11 & 12 of the Ac....