Sec 154 Cannot Be Used to Deny Sec 11 Exemption on Form 10B Delay – ITAT Restores Benefit

Tehmina K. Katrak Charitable Trust Vs ITO (ITAT Mumbai) Sec 154 Cannot Be Used to Deny Sec 11 Exemption on Form 10B Delay – ITAT Restores Benefit Assessee trust claimed exemption u/s 11. Return was filed within extended due date (CBDT Circular 1/2022). CPC initially allowed exemption u/s 143(1), but later rectified u/s 154 denying exemption alleging delay in filing Form 10B. ITAT held: Assessee had attempted filing Form 10B within time; delay due to portal technical issues CPC had already examined & accepted explanation in 143(1) stage Subsequent action u/s 154 amounts to review of ...