DTVSV Accepted – 263 Quashed: ITAT Pune Holds CIT(E) Cannot Revise After Issuing Form-4

Prabodh Centre for Rural Reforms Vs CIT (Exemption) (ITAT Pune) In this appeal, Prabodh Centre for Rural Reforms, a charitable trust, challenged the revisional order passed u/s 263 by CIT(Exemption), Pune. The reassessment u/s 143(3) r.w.s.144B had taxed interest income arising from alleged impermissible investments at Maximum Marginal Rate, as the trust had invested ₹85 lakh in a concern in which a trustee had substantial interest, attracting section 11(5). The AO, relying on binding precedents including Sheth Mafatlal Gagalbhai Foundation Trust (Bom HC) & Fr. Mullers Charitable Institu...