2021 (7) TMI 720

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....This appeal by the revenue is preferred against the order of the CIT(A), Dehradun dated 16.03.2018 pertaining to A.Y. 2014-15. 2. The only grievance of the revenue read as under:- 1. The Ld. CIT(A) has erred in law and facts in deleting the additions of Rs. 6,43,93,753/- made by the AO against surplus of income while the assessee was holding a valid certificate u/s. 12A of the I.T. Act. 3. Bri....

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....r before the CIT(A) and furnished all the relevant documents/certificates for the eligibility of section 11 of the Act. After considering the submissions and the relevant documentary evidences the CIT(A) held as under:- "15. After going through all the documents, the observations and conclusions of the undersigned are as below. It may also be mentioned that the submissions of the assessee were s....

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....ecision of the Supreme Court of India in Nagpur Hotel Owners Association 247 ITR 201 saying that delay in submitting Form 10 for claim of exemption u/s. 11 can be condoned and the form can be submitted on a later date. 17. The assessee has regularly received benefit u/s. 80G and exemption u/s. 10(23C) has also regularly been issued in favour of the assessee. These benefits would not have been ex....

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....ent itself). The assessee has applied for the fresh registration u/s. 12A only because the earlier order went missing. The Uttarakhand floods are well known natural calamity and that certain documents of the assessee went missing in that, is a completely acceptable explanation. Under these circumstances, the addition made by the AO is deleted." 6. Before us though the DR strongly supported the as....