Synthetic & Art Silk Mills Research Association. v. CIT (2024) 205 ITD 70 (Mum)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Examined all details-Possible view-Revision is not valid.[S. 10(21)]

Assessee, a charitable trust, which is engaged in was engaged in Scientific research associations conducting research and development activities in textile sector. It claimed exemption under section 10(21).Assessing Officer accepted assessee’s claim. Commissioner (E) was of view that income derived by assessee from Auditorium Hire charges, hoarding site and service charges, and rent was not incidental to objectives of assessee-trust and, thus, not eligible for exemption under section 10(21). On appeal the Tribunal held that   since issue as to whether impugned income was incidental to objects of assessee-trust was a debatable issue, revisionary authority was not justified in setting aside order of Assessing Officer.  (AY. 2013-14)

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