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Section 260A2 Section 1482 Section 12A2 Exemption2 Addition to Income2

THE COMMISSIONER OF INCOME TAX (EXEMPTIONS) vs. THE TIBETIAN CHILDREN VILLAGE

Accordingly the same are dismissed alongwith pending

ITA/29/2019HC Himachal Pradesh22 Aug 2023

Bench: HONOURABLE THE CHIEF JUSTICE MAMIDANNA SATYA RATNA SRI RAMACHANDRA RAO,HON'BLE MR. JUSTICE AJAY MOHAN GOEL

For Appellant: Mr. Vinay Kuthiala, Senior Advocate with

Section 12ASection 148Section 260A

1. Whether on facts and in the circumstances of the case and in law, the Hon’ble ITAT is justified in treating the notice 4 under Section 148 as invalid on the ground that the notice was based only on change of opinion and there was no escapement of income? 2. Whether on facts and in the circumstances

THE COMMISSIONER OF INCOME TAX (EXEMPTIONS) vs. THE TIBETIAN CHILDREN VILLAGE

Accordingly the same are dismissed alongwith pending