TMI Blog2022 (11) TMI 255X X X X Extracts X X X X X X X X Extracts X X X X ..... f the judgment delivered by this court [ 2022 (10) TMI 948 - SUPREME COURT] that para 254 of the judgment should be such as to enable the Revenue to redo the assessments in accordance with the above judgments for the past and examine the eligibility on a yearly basis for the future and thus render justice HELD THAT:- A plain reading of the conclusions recorded in Para 253 (A)(B)(C) (D) and (E ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... context, which is that they apply for the assessment years in question, which were before this court and were decided; wherever the appeals were decided against the revenue, they are to be treated as final. The reference to future application has to be understood in this context, which is that for the assessment years which this court was not called upon to decide, the concerned authorities will ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... basis for the future and thus render justice. 2. This court, by the judgment in question, had considered and pronounced upon the interpretation of Section 2 (15) of the Income Tax Act, 1961, in relation to charitable trusts which engage in activities that further objects of general public utility. The activities and cases of various kinds of charities, trusts and organizations, including sta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... missal of the revenue s appeals will preclude an examination of the merits for these assesses in future, as well. 4. A plain reading of the conclusions recorded in Para 253 (A)(B)(C) (D) and (E) would disclose that this court consciously recorded its findings, with the intent of finally deciding the issues, for various organizations- in relation to the assessment years in question, - whereas in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eated as final. However, the reference to future application has to be understood in this context, which is that for the assessment years which this court was not called upon to decide, the concerned authorities will apply the law declared in the judgment, having regard to the facts of each such assessment year. In view of this discussion, no further clarification is necessary or called for. 6. ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
