Charitable Trust's Tax Exemption Denied for Late Filing; Tribunal Allows Appeal for Delay Due to Technical Issues.

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....Denial of exemption u/s 11(2) was contested due to the trust's failure to file Form No. 10 within the due date specified u/s 139(1) owing to technical issues. The provisions of section 11(2) mandate charitable trusts to apply a specified percentage of income for charitable purposes, with an option to accumulate or set apart the prescribed percentage for application in India, subject to conditions. The issue centered on whether furnishing the statement in the prescribed Form No. 10 on or before the due date of filing the return is mandatory or directory in nature for availing exemption u/s 11(2). Relying on the Supreme Court's decision in PCIT vs. Wipro Ltd., which held furnishing the prescribed form within the due date as mandatory for clai.........