2025 (2) TMI 1584

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ue : Dr. K.R. Subhash, CIT-DR ORDER PER B.R. BASKARAN, A.M : The assessee has filed this appeal challenging the revision order dated 06-03-2024 passed by the Ld CIT(Exemptions), Mumbai u/s 263 of the Income tax Act and it relates to the Assessment Year (AY.) 2018-19. The assessee is challenging the validity of revision order so passed by Ld CIT(E). 2. The appeal is barred by limitation....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d it is registered u/s 12A of the Act. It is an association of advertisement agencies regulating the advertisement practices in India. It also functions as a dispute/complaint mediatory agency to monitor the various complaints and to maintain sanctity of advertisements in various media. It filed its return of income declaring NIL income after claiming exemption u/s 11 of the Act. During the course....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....eet, the AO has shown gross receipts, the deduction u/s 11(1)(a), 11(2) etc and shown total income as NIL. However, the AO brought to tax the above said amount of Rs. 89,87,370/- and also long term capital gains of Rs. 1,62,20,500/-. 4. The Ld CIT(E), upon examination of assessment record, took the view that the AO has allowed exemption u/s 11 of the Act to the assessee, after having held that ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....out the deductions claimed u/s 11 in the tax computation sheet and it appears, the same has created confusion. We notice from the body of the assessment order that the AO has categorically held that the assessee is not eligible for exemption u/s 11 of the Act, but excluded the receipts/expenditure which is covered by the mutuality principle. Thus, the reasoning given by the Ld CIT(E) for revising ....