100-Month Delay Condoned – ITAT Slams Gross Taxation, Says “Only Net Income Can Be Taxed”

SJJPP Rashitrya S Trust Vs ITO (ITAT Bangalore) In the case of SJJPP Rashtriya S Trust, the Bangalore ITAT dealt with massive delay (over 100 months) in filing appeal and incorrect taxation of gross receipts of a charitable trust. The CIT(A) had dismissed the appeal in limine solely on delay, without examining merits. The ITAT took a different view: Applied liberal principles of condonation laid down by the Supreme Court. Held that technicalities should not defeat substantial justice. Noted delay was due to bona fide belief (rectification pending, lack of communication) and not mala fide. Con...