Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2019 (6) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2019 (6) TMI 1637 - AT - Income TaxExemption u/s 11 - charitable activity u/s 2(15) - claim of accumulation under section 11(2) - denial of claim as activity of the assessee involves advancement of any other abject of general public utility and its receipts exceeds the mandatory limit as specified under proviso to section 2(15) - THAT:- As decided in own case [2018 (10) TMI 1915 - ITAT AHMEDABAD] there is no change in the facts and circumstances in the impugned case in comparison to the previous assessment years and the Revenue in earlier year has accepted the same. Therefore in our considered view the principles of consistency should be applied. In this regard we find principles laid down in the judgment of Hon'ble Supreme Court in the case of Radhasoami Satsang vs. Commissioner of Income Tax [1991 (11) TMI 2 - SUPREME COURT] are directly attracted to the instant case wherein it was observed that in the absence of any material change in the facts, the Revenue should not take a different view in the other year. Appeal of the revenue is dismissed.
|