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Issues involved: The judgment involves three appeals before the Appellate Tribunal ITAT Delhi, including quantum appeals, penalty appeal, and the deletion of additions and penalties u/s 271(1)(C) of the Income Tax Act.
ITA No. 5075 - Quantum Appeals: The revenue appealed against the deletion of additions totaling Rs. 40,50,850 and Rs. 39,50,621. The assessee, a trust, had its registration U/S 12 A A (2) canceled, but later reinstated. The Assessing Officer made additions due to lack of registration, treating donations and income over expenditure as taxable. However, the Ld. CIT (A) deleted these additions based on the reinstated registration, allowing benefits under Section 11 and 12 of the IT Act. The ITAT upheld this decision, emphasizing the genuine charitable objectives of the trust. ITA No. 5076 - Quantum Appeals: The revenue contested the deletion of a Rs. 1,78,01,645 addition received as a corpus donation, citing lack of registration U/S 12AA. Similar to the previous appeal, the Ld. CIT (A) deleted the addition based on the reinstated registration and the trust's charitable activities. The ITAT concurred with this decision, finding no grounds to interfere. ITA No. 5077 - Penalty Appeal: The revenue challenged the deletion of a penalty imposed u/s 271(1)(C) of the Income Tax Act. The penalty was annulled as the quantum additions were deleted, rendering the penalty baseless. The ITAT upheld the Ld. CIT (A)'s decision, stating that once the additions were removed, no tax evasion existed to warrant a penalty. Consequently, all three appeals were dismissed.
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