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Case Law Details

Case Name : Bhutakia Bhimasar Vs PCIT (ITAT Ahmedabad)
Appeal Number : ITA No. 102/Ahd/2021
Date of Judgement/Order : 14/06/2023
Related Assessment Year :
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Bhutakia Bhimasar Vs PCIT (ITAT Ahmedabad)

Introduction: The Income Tax Appellate Tribunal (ITAT) in Ahmedabad has made a significant decision in the Bhutakia Bhimasar Vs Principal Commissioner of Income Tax (PCIT) case. The Tribunal stressed that a charitable organization should not be deprived of tax exemption benefits under section 11 of the Income Tax Act 1961, solely due to technical lapses.

Analysis: The ITAT, while condoning an extraordinary delay in filing the appeal, considered the merits of the case rather than dismissing it on the grounds of technicalities. Drawing guidance from the precedent set in the case of S.R. Koshti Vs. CIT, the tribunal emphasized that the authorities under the Act must ensure only legitimate taxes due are collected, even if the assessee commits a mistake or is over-assessed.

This ruling upholds the principle that a meritorious case should not be discarded based on limitation. The court further noted that the assessee, being a charitable organization, should not be deprived of the benefit of exemption under section 11 of the Act due to technical lapses.

Conclusion: The ITAT Ahmedabad’s ruling in Bhutakia Bhimasar Vs PCIT is a significant judgment, reaffirming the principles of natural justice. It highlights that the technicalities of filing an appeal should not obstruct the legitimate exemptions for which a charitable organization is entitled.

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