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Issues:
1. Whether the Hindu deity is considered an artificial juridical person under the Income-tax Act? 2. Whether the assessee Trust is entitled to deduction under section 80L of the Income-tax Act? Analysis: 1. The appeal raised two primary issues. Initially, the assessee-trust declared its status as AOP (Trust) in the return of income, which was later regularized under section 148 since it was filed after the time limit under section 139. The Assessing Officer disallowed the deduction claimed under section 80L and computed the income of the trust at a higher amount due to various reasons, including the absence of registration under section 12A. The CIT(A) accepted the contention that the Hindu deity was an artificial juridical person falling within the definition of 'individual' in section 3 of the Act. The CIT(A) held that the Hindu deity could be assessed as an individual, allowing for a different tax rate and deduction under section 80L. 2. The Trust Deed revealed the establishment of the trust for religious purposes under the Bombay Public Trusts Act. The Trust's objects included promoting Hindu Vaidic Religion, maintaining temples, and spreading religious awareness. The CIT(A) considered the trust as a public religious trust based on legal precedents. Despite the assessee's argument that the deity should be treated as an individual for tax purposes, the CIT(A) concluded that the status should be that of AOP. However, since the income derived was for charitable or religious purposes, section 164(2) applied, taxing the income as that of an AOP but at the rates applicable to individuals. The CIT(A) also allowed the deduction under section 80L following a decision by the Bombay High Court regarding public charitable trusts. In conclusion, the appeal was partially allowed, with the CIT(A) affirming the status of the assessee as an AOP for taxation purposes but applying favorable tax rates and allowing the deduction under section 80L based on legal interpretations and precedents.
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