TMI Blog1992 (9) TMI 69X X X X Extracts X X X X X X X X Extracts X X X X ..... r section 256(1) of the Income-tax Act, 1961, for the opinion of the court : "1. Whether, on the facts and in the circumstances of the case, the Tribunal is justified in holding that the income derived by the Radhaswami Satsang, a religious institution, is entitled to exemption under sections 11 and 12 of the Income-tax Act, 1961 ?" 2. Whether the Appellate Tribunal was legally correct in holdin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the process of assessment and, therefore, it is open to an assessee to dispute the levy in appeal, provided he limits himself to the ground that he is not liable to the levy at all. The assessee-trust being entitled to exemption in view of the aforementioned Supreme Court decision, the liability to be assessed is fully denied by the assessee-trust and, therefore, we hold that the Appellate Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X
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