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Case Law Details

Case Name : Karma Falya Trust Vs DCIT (ITAT Ahmedabad)
Appeal Number : ITA No. 10/Ahd/2023
Date of Judgement/Order : 05/01/2024
Related Assessment Year : 2018-19
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Karma Falya Trust Vs DCIT (ITAT Ahmedabad) 

Introduction: The recent ruling by the Income Tax Appellate Tribunal (ITAT) Ahmedabad in the case of Karma Falya Trust vs. DCIT sheds light on the implications of failure to file an audit report along with the return of income. This article delves into the details of the case, analyzing the grounds of appeal, arguments presented, and the tribunal’s decision.

Detailed Analysis: The appeal filed by Karma Falya Trust contested the order passed by the Commissioner of Income Tax (Appeals) for the Assessment Year 2018-19. The primary issue revolved around the denial of exemption under Section 11 of the Income Tax Act due to the non-filing of an audit report along with the income tax return.

Despite the trust obtaining the audit report well before the return filing date, it was not submitted on the Income Tax Portal until a later date. Consequently, the exemption claimed by the trust was disallowed during the assessment proceedings.

During the appellate process, the trust argued that the delay in filing the audit report should not result in the denial of exemption under Section 11. Citing precedents and legal provisions, the trust contended that the filing of the audit report should be considered a procedural requirement rather than a substantive condition for claiming exemption.

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