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1985 (1) TMI 11

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..... king a reference to this court concerning the question whether the sum of Rs. 1,59,959 expended by the assessee was entitled to exemption under section II of the Income-tax Act, 1961. It may be mentioned that the assessee in this case is a charitable institution registered by the Commissioner under section 80G. It also appears that the object of the trust was to commemorate the services rendered b .....

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..... t years 1970-71, 1971-72 and 1972-73. The Tribunal has noted in its order that there was no change in law and it was unjust on the part of the Department to take a different view suddenly and levy heavy tax on the assessee when it was the same project going on for all this period. It was observed by the Privy Council in Trustees of the Tribune Press v. CIT [1939] 7 ITR 415 (PC), that whether a .....

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