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| The Tax Publishers2020 TaxPub(DT) 0094 (Del-Trib) INCOME TAX ACT, 1961,
Section 11(1)(c)
Though AO made additions under section 11(1)(c) on the ground that assessee had failed to get approval of CBDT for exemption under section 11(1)(c), but the approval had been accorded by CBDT vide letter, therefore, the additions were rightly deleted by CIT(A).
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Charitable trust - Exemption under section 11 - Approval of CBDT -
AO made additions under section 11(1)(c) on the ground that assessee had failed to get approval of CBDT for exemption under section 11(1)(c), but CIT(A) deleted the addition. Held: It was proved that the approval had been accorded by CBDT vide letter No. E. No. 180/04/2011-ITA-1 dt. 08-2-2016, which was effective for assessment years 2011-12 and 2012-13, the years under assessment to incur the expenses respectively by the assessee outside India for purpose of International Welfare and the same had been ordered to be included in the total income of the assessee. Since aforesaid factual position had not been controverted by department. Thus, no illegality or perversity was found in findings written by the CIT(A) in deleting the additions.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Sections 11 to 13
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