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2020 (8) TMI 46 - AT - Income TaxReopening of assessment u/s 147 - Exemption u/s 11 - assessee is a Trust engaged in Urban Development activity as per the Government Regulations - HELD THAT:- In the original assessment orders, the AO has also allowed benefit of sections 11 and 12 to the assessee. These orders have been reopened by the AO by issuance notice under section 148 of the Act. We have noticed the above facts while dealing with the issues in the appeal of Revenue on the merit of reopening. The income of the assessee was determined at NIL in the original assessment orders for both the years. Considering the order of co-ordinate Bench in the Asstt.Year 2011-12 [2019 (7) TMI 1608 - ITAT AHMEDABAD] we are of the view that the assessee is entitled to benefit of sections 11 and 12, and therefore, the issue on merit also deserves to be decided in favour of the assessee.
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