Arya Samaj G.K.-II (Regd.) Vs ITO (Exemption) (ITAT Delhi)
The appeal of Arya Samaj G.K.-II, a registered charitable trust, was brought before the ITAT Delhi concerning the disallowance of deductions under sections 11 and 12A of the Income Tax Act for the Assessment Year 2014-15. The trust had filed its return online, declaring ‘Nil’ income after claiming various exemptions. However, during the processing of the return under section 143(1), certain typographical errors in the filing led to the disallowance of deductions, including Rs. 804,742 under section 11(1), Rs. 700,000 under section 11(2), and Rs. 318,428 under section 12A. The appellant contended that these mistakes were clerical errors, and the trust is still registered under section 12A, entitled to claim exemptions as per the Income Tax provisions. Despite the corrections requested under section 154, the Assessing Officer and the Commissioner of Income Tax (Appeals) rejected the request, citing that the mistakes in the return led to improper claims.
In its ruling, the ITAT Delhi emphasized that while clerical errors were made in the filing, such mistakes should not result in the denial of statutory benefits to the trust. It noted that Arya Samaj G.K.-II is indeed registered under section 12A, and the necessary forms, such as Form 10B, had been filed. The Court directed the Assessing Officer to verify the claims of the trust and compute the income according to the applicable laws, granting the exemptions under sections 11 to 13. The appeal was allowed for statistical purposes, meaning the trust’s claim for exemption should be reconsidered based on the actual facts and not on procedural mistakes. This case highlights the importance of accurate filing but also the necessity for due consideration of minor clerical errors when statutory benefits are involved.
