Revisional relief for omitted charitable-trust capital-gains claims extends to fixed-deposit reinvestment where disclosure was complete.
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....Revisional jurisdiction under section 264 extends to relief omitted from a return where a charitable trust later identifies an error causing over-assessment. Voluntary disclosure of income as taxable does not bar reconsideration if the trust disclosed the capital gains and relevant particulars without suppressing material; the revisional authority must examine entitlement under law. For charitable-trust capital gains, reinvestment of net sale consideration in a bank fixed deposit for six months or more is treated as acquisition of another capital asset under Instruction No. 883. Conditions under public-trust law cannot be imported to deny this standalone exemption.....
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