ITAT Cannot Uphold Section 263 Revision on Grounds Not Raised by Commissioner: Kerala HC

Save A Family Plan (India) Vs DCIT (Exemptions) (Kerala High Court) The case involves an appeal by a charitable trust registered under Section 12A of the Income Tax Act, 1961, claiming benefits under Section 11 of the Act. During the financial year 2013-14 (Assessment Year 2014-15), the appellant received domestic and foreign donations and distributed donations to 72 other institutions, also registered under Section 12A. The Assessing Officer, upon examining the appellant’s accounts, accepted the return of income in the assessment order dated 30.12.2016. Subsequently, the Commissioner of Inc...