Delay Condoned Because Temple Believed Income Was Exempt Under Section 10(23BBA)

Ujjaini Mahakali Devasthanam Vs ITO (ITAT Hyderabad)

192-Year-Old Government-Administered Temple – 607-Day Delay Condoned; Reopenings & 271B Penalties Remanded as AO Earlier Granted 10(23BBA) Exemption

In these six appeals—two against reassessment orders u/s 147 r.w.s.144 & four against penalties u/s 271B—the Assessee, a 192-year-old temple under the Telangana Endowments Act, explained a 607-day delay in filing appeals. Tribunal noted that the temple is administered entirely by the State Government, its PAN was wrongly created as “Firm,” & it was under

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