Pr. CIT v. Silver Line and Anr.

283 CTR 148High Court2016#6443 most cited
18

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Sections most often in play

Section 143(2)Section 143(3)Section 147Section 148Section 144Section 142(1)Section 144BSection 292BB

Issues it is cited on

section 144(1)(b)section 148(1)section 144(1)section 292bbsection 158bbsection 158bcsection 292bblock periodprincipal commissioner of income-taxsection 292section 158bsection 158

Judgments citing Pr. CIT v. Silver Line and Anr.

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 142/RPR/2026[2014-15]Status: DisposedITAT Raipur24 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

…otice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT v. Silver Line and Anr.: 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. Pawan Gupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of…

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 141/RPR/2026[2013-14]Status: DisposedITAT Raipur24 Mar 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

…otice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT v. Silver Line and Anr.: 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. Pawan Gupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of…

MOHAMMED USMAN, BHILAI,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, DURG

In the result, appeal of the assessee is allowed

ITA 180/RPR/2026[2011-12]Status: DisposedITAT Raipur17 Mar 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.180/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 Mohammed Usman C/25, Nandini Road, Power House, Bhilai-490 011, Dist. Durg Pan: Aafpu9292H

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 148

…otice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT v. Silver Line and Anr.: 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. Pawan Gupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of…

RAMA AGRAWAL, DURG,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, DURG

In the result, appeal of the assessee is allowed

ITA 490/RPR/2025[2015-16]Status: DisposedITAT Raipur25 Sept 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.490/Rpr/2025 "नधा"रण वष" /Assessment Year : 2015-16 Rama Agrawal 33A, I. E. Bhilai, S.O Industrial Estate, Durg-490 026 (C.G.) Pan: Acgpa8359N

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 144Section 147Section 148

…otice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT v. Silver Line and Anr.: 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. Pawan Gupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of…

HARJEET SINGH CHHABRA, RAIPUR,RAIPUR vs. ITO, WARD-1, RAIPUR (ERST. ITO-1(3), RAIPUR), RAIPUR

In the result, appeal of the assessee is allowed

ITA 469/RPR/2025[2013-14]Status: DisposedITAT Raipur09 Sept 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.469/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Harjeet Singh Chhabra H. No.84, Las Vista, Mahaveer Nagar, Raipur (C.G.)-492 001 (C.G.) Pan: Adkpc0408P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Central Circle-1, Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Hardik Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 127Section 143(2)Section 143(3)Section 144Section 147Section 148Section 4

…otice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT v. Silver Line and Anr.: 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. Pawan Gupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of…

SATYA ENTERPRISES,BILASPUR vs. INCOME TAX OFFICER, WARD-1(2), BILASPUR, BILASPUR

In the result, appeal of the assessee is allowed

ITA 396/RPR/2025[2017-18]Status: DisposedITAT Raipur03 Sept 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.396/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Satya Enterprises Ward No.3, Shanti Nagar, Bilaspur (C.G.)-495 001 Pan: Adcfs1415L .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 144Section 148Section 292B

…otice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT v. Silver Line and Anr.: 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. Pawan Gupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a 7 Satya Enterprises Vs. ITO, Ward-1(2), Bilaspur notice under Section 143(2) of the Act for proceeding further. It is thus not open for the…

ANIL KUMAR PAREKH, DHAMTARI,DHAMTARI vs. INCOME TAX OFFICER, WARD DHAMTARI, DHAMTARI

In the result, appeal of the assessee is allowed

ITA 194/RPR/2025[2013-14]Status: DisposedITAT Raipur28 Jul 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.194/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Anil Kumar Parekh C/O. Madhu Traders, Station Road, Dhamtari (C.G.)-493 773 Pan: Akepp0240E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-Dhamtari (C.G.) ……""यथ" / Respondent

For Appellant: None (Adjournment Application)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(2)Section 147Section 148Section 68Section 69C

…otice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT v. Silver Line and Anr.: 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. Pawan Gupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of…

KRISHAN KUMAR MAKRANIA PRO. M/S. MAKRANIA OIL MILL,,BHIWANI vs. DCIT CENTRAL CIRCLE-I, GURGAON

In the result, assessee’s appeal in ITA No

ITA 3214/DEL/2024[2011-12]Status: DisposedITAT Delhi18 Jun 2025AY 2011-12

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singhassessment Year: 2011-12)

For Appellant: Sh. Gautam Jain, Adv. & AnkitFor Respondent: Sh. Om Parkash, Sr. DR
Section 139(1)Section 143(2)Section 143(3)Section 147Section 148

…otice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT v. Silver Line and Anr.: 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. Pawan Gupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of…

INDIAN CLOTHING LEAGUE(P) LTD.,NOIDA vs. ITO, WARD-26(2), NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 505/DEL/2020[2011-12]Status: DisposedITAT Delhi21 Feb 2022AY 2011-12

Bench: Shri R.K. Pandaassessment Year: 2011-12 Indian Clothing League (P) Ltd., Vs. Ito, Rupinder Kumar Aggarwal, Ward-26(2), Advocate, B-1A/22H, New Delhi. Sector-51, Noida. Pan: Aaccv3439R (Appellant) (Respondent) Assessee By : Shri Lalit Mohan, Ca Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 01.02.2022 Date Of Pronouncement : 21.02.2022 Order

For Appellant: Shri Lalit Mohan, CAFor Respondent: Shri Om Parkash, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

…otice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT v. Silver Line and Anr.: 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. Pawan Gupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of…

HARI GANGA FINCAP PVT. LTD.,NEW DELHI vs. ITO, WARD- 11(1), NEW DELHI

In the result appeal of the assessee is allowed

ITA 2314/DEL/2018[2011-12]Status: DisposedITAT Delhi13 Sept 2021AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing) Hari Ganga Fincap Pvt. Ltd, Vs. Ito, Raj Kumar & Associates, Ca, L- Ward-11(1), 7A, (Lgf), South Extn. Part-Ii, New Delhi New Delhi Pan: Aaach6775J (Appellant) (Respondent)

For Appellant: Shir Raj Kumar, CAFor Respondent: Ms. Anima Barnwal, Sr. DR
Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 68Section 69Section 69C

…evidence is produced by the revenue either before the ld CIT(A) or before us, therefore he submitted that the whole proceedings are without jurisdiction. He referred to the decision of the Hon'ble Delhi High Court on that issue in case of DCIT Vs. Silverline 283 CTR 148 (Del). 6. As this is the jurisdictional issue the ld DR was questioned whether there were any notice u/s 143(2) of the Act. He submitted that the ld CIT(A) has specifically rejected this ground of the assessee. He relied on the order of the lower authorities. 7. We have carefully considered the rival contention of the parties and perused the orde…

DART INFRABUILD PVT. LTD.(EARLIER KNOWN AS KIWI INFRABUILD PVT. LTD.),NEW DELHI vs. ITO WARD-14(3), NEW DELHI

In the result, appeal of the assessee is allowed

ITA 8774/DEL/2019[2010-11]Status: DisposedITAT Delhi25 Aug 2020AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri K.N. Chary

Section 143(2)Section 147Section 148Section 14ASection 151Section 151(1)Section 271(1)(c)Section 68

…e such notice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT Silver Line and 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321 ITR 362 (SC) and CIT v. PawanGupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of…

M/S. BARIPADA URBAN COOPERATIVE BANK LTD.,BARIPADA vs. ACIT, BALASORE CIRCLE, BALASORE., BALASORE

In the result, the appeal filed by the assessee is allowed

ITA 532/CTK/2013[2009-10]Status: DisposedITAT Cuttack11 Jul 2017AY 2009-10

Bench: S/Shri N.S Saini & Pavan Kumar Gadaleassessment Year : 2009-2010 Baripada Urban Co-Operative Vs. Acit, Balasore Circle, Bank Ltd., At: Roxy Road, Balasore. Baripada Pan/Gir No. Aabat 2673 C (Appellant) .. ( Respondent)

For Appellant: Shri B.Panda/B.R.Panda, ARsFor Respondent: Shri Kunal Singh, CIT DR
Section 143(2)Section 143(3)

…nd that notice has not been issued by the Competent Authority as required in the Statute. In this connection, we are putting our reliance in the judgment of Hon'ble High Court of Delhi in the case of Principal Commissioner of Income Tax vs. Silver Line (2016) 283 CTR 148 (Del), wherein the extract portion reproduced below:- "With the legal position being abundantly clear that a reassessment order cannot be passed without compliance with the mandatory requirement of notice being issued by the AO to the Assessee under Section 143(2) of the Act, the ITAT was in the present case right in concluding that the reassess…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(4), BANGALORE vs. M/S INDO AMERICAN HYBRID SEEDS INDIA P LTD, BANGALORE

ITA 1283/BANG/2014[2009-10]Status: DisposedITAT Bangalore11 Aug 2016AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raodeputy Commissioner Of Income-Tax, Circle 11(4), Bangalore. … Appellant Vs. M/S.Indo American Hybrid Seeds India Pvt.Ltd. Pb No.7099, 7Th Km, Banashankari-Kengeri Link Road,Channasandra Village, Subramanyapura Po, Bangalore-560001. … Respondent Pa No.Aaaci 4027 J & Cross Objn.No.142/Bang/2015 (In Ita No.1283/Bang/2014) (Assessment Year: 2009-10) (By The Assessee)

For Appellant: Shri S.Annamalai, AdvocateFor Respondent: Shri Sunil Kumar Agarwal,JCIT(DR)
Section 115JSection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 148Section 292B

…isions of section 292BB are applicable only in respect of service of notice and does not cover the case of issue of notice. In support of this proposition, he relied on the decision of the Hon’ble Delhi High Court in the case of Principal CIT vs. Silver Line (283 CTR 148) and the decision of the Hon’ble Allahabad High Court in the case of Nawal Kishore & Sons Jewellers vs. CIT (2012) 79 DTR 241)(All.) 8. We heard rival submissions and perused the material on record. The only issue that arises for consideration in the present appeal is whether the notice u/s 143(2) was issued before ITA No.1283/B/2014 & CO No.14…

M/S PRINT-FAB (INDIA) P. LTD.,,NEW DELHI vs. ITO, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 5751/DEL/2013[2003-04]Status: DisposedITAT Delhi27 Jul 2016AY 2003-04

Bench: Smt. Diva Singh & Sh. O.P. Kantassessment Year: 2003-04 M/S. Print-Fab (India) P. Vs. Income Tax Officer, Ward Ltd., 46/8, 1St Floor, East 14(4), New Delhi Patel Nagar, New Delhi Gir/Pan : Aaccp7299M (Appellant) (Respondent) Appellant By Sh. Satyen Sethi, Adv. Respondent By Sh. V. R. Sonbhadra, Sr.Dr Date Of Hearing 21.06.2016 Date Of Pronouncement 27.07.2016 Order Per O.P. Kant, A.M.: This Appeal By The Assessee Is Directed Against Order Dated 12/08/2013 Of Learned Commissioner Of Income-Tax (Appeals)-Xvii, New Delhi, For Assessment Year 2003-04, Raising Following Grounds, Which Are Revised On 22.02.2016: 1. That On The Facts & Circumstances Of The Case & In Law, The Commissioner Of Income-Tax (Appeals)-Xvii, New Delhi [Briefly "The Cit(A)"] Has Erred In Upholding The Reopening Of Assessment Under Section 147 Of The Income Tax Act, 1961 (Briefly "The Act"). 2. That On The Facts & Circumstances Of The Case & In Law, The Cit(A) Has Erred In Not Appreciating That The Assessment Was Not Validly Reopened, For No Valid Notice

Section 143(2)Section 147Section 148Section 68

…ue such notice under Section 143(2). In our view, this contention is bereft of any merits and completely ignores the scheme of the machinery provisions for assessment under the Act. It is now well settled by a number of decisions (See: Pr. CIT Silver Line and 283 CTR 148 (Del), ACIT v. Hotel Blue Moon: 321ITR 362 (SC) and CIT v. PawanGupta: 318 ITR 322 (Del)) that whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice under Section 143(2) of the Act for 7 AY: 2003-04 proceeding further. It is thus not open for the AO to not issue a notice under Secti…

ITO, WARD - 56(4), KOLKATA, KOLKATA vs. M/S. NOPANY & SONS, KOLKATA

In the result, assessee’s appeal is allowed

ITA 1621/KOL/2011[2007-08]Status: DisposedITAT Kolkata20 Jul 2016AY 2007-08

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 127Section 142(1)Section 143(2)Section 143(3)Section 292B

…nd that notice has not been issued by the Competent Authority as required in the Statute. In this connection, we are putting our reliance in the judgment of Hon’ble High Court of Delhi in the case of Principal Commissioner of Income Tax vs. Silver Line (2016) 283 CTR 148 (Del), wherein the extract portion reproduced below:- “With the legal position being abundantly clear that a reassessment order cannot be passed without compliance with the mandatory requirement of notice being issued by the AO to the Assessee under Section 143(2) of the Act, the ITAT was in the present case right in concluding that the reassess…

M/S. NOPANY & SONS,KOLKATA vs. ITO, WARD - 56(4), KOLKATA, KOLKATA

In the result, assessee’s appeal is allowed

ITA 1301/KOL/2011[2007-08]Status: DisposedITAT Kolkata20 Jul 2016AY 2007-08

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Ravi

Section 127Section 142(1)Section 143(2)Section 143(3)Section 292B

…nd that notice has not been issued by the Competent Authority as required in the Statute. In this connection, we are putting our reliance in the judgment of Hon’ble High Court of Delhi in the case of Principal Commissioner of Income Tax vs. Silver Line (2016) 283 CTR 148 (Del), wherein the extract portion reproduced below:- “With the legal position being abundantly clear that a reassessment order cannot be passed without compliance with the mandatory requirement of notice being issued by the AO to the Assessee under Section 143(2) of the Act, the ITAT was in the present case right in concluding that the reassess…

CIT vs. DELHI KALYAN SAMITI

ITA/697/2015HC Delhi22 Mar 2016

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

Section 1Section 12ASection 142(1)Section 143(2)Section 144Section 147Section 148Section 260A

…ove conclusion is disputed and it is further contended on behalf of the Assessee ITA Nos. 696, 697 & 699/2015 Page 2 of 8 7 that the issue stands fully covered by the decision of this Court in Principal Commissioner of Income Tax v. Silver Line (2016) 283 CTR 148 (Del). 4. The relevant facts necessary to consider the aforesaid controversy are as under: 4.1. The Assessee is a society promoted by the Government of National Capital Territory of Delhi and was registered under the Societies Registration Act on 31s March, 1995. The Assessee applied for registration under Section 1 2A of the Income Tax Ac…

CIT vs. DELHI KALYAN SAMITI

ITA/696/2015HC Delhi22 Mar 2016

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

Section 1Section 12ASection 142(1)Section 143(2)Section 144Section 147Section 148Section 260A

…ove conclusion is disputed and it is further contended on behalf of the Assessee ITA Nos. 696, 697 & 699/2015 Page 2 of 8 7 that the issue stands fully covered by the decision of this Court in Principal Commissioner of Income Tax v. Silver Line (2016) 283 CTR 148 (Del). 4. The relevant facts necessary to consider the aforesaid controversy are as under: 4.1. The Assessee is a society promoted by the Government of National Capital Territory of Delhi and was registered under the Societies Registration Act on 31s March, 1995. The Assessee applied for registration under Section 1 2A of the Income Tax Ac…