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2020 (1) TMI 1356 - GUJARAT HIGH COURTReopening of assessment u/s 147 - charitable activity u/s 2(15) - HELD THAT:- The activity of the petitioners cannot be said to be carrying on any activity in the nature of trade, commerce or business, so as to apply proviso to Section 2(15) which defines 'charitable purpose'. Therefore, the impugned notice as well as the assessment order passed by the respondent are required to be quashed and set aside. The petitions, therefore, succeed and are accordingly allowed. The impugned notice issued by the respondent under Section 148 of the Act is therefore quashed and set aside - Decided in favour of assessee.
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