Temple Trust Exemptions u/s 11 & 12 allowed due to inapplicability of 12A(1)(ba) amendment for AY 2017-18

Siddhanath Mahadev Temple Trust Vs CIT(Exemption) (ITAT Surat)

Conclusion: Clause (ba) of sub-section (1) of section 12A was applicable for AY.2018-19 onwards and not for AY.2017-18, assessee-temple trust was entitled to tax exemptions under Sections 11 and 12 . Hence, the order of AO was not erroneous and prejudicial to the interests of revenue and therefore, it was not amenable to revision u/s 263.

Held: Assessee had not filed its return of income u/s 139. It filed the return of income, declaring total income of Rs.10,27,436/-only after re

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