Section 263 Revision Invalid as AO Already Examined Accumulated Fund Utilization: Bombay HC

CIT (Exemptions) Vs Impact Foundation (India) (Bombay High Court) Summary: The Bombay High Court dismissed the Revenue’s appeal and upheld the ITAT order quashing revisionary proceedings initiated under Section 263 against a charitable institution claiming exemption under Sections 11 and 12AA. The dispute concerned utilization of ₹6 crore out of accumulated funds under Section 11(2), which the CIT (Exemptions) alleged was not properly verified during assessment. The Court held that the Assessing Officer had conducted detailed enquiries through notices, examined Form 10, board resolutions,...