164 of 2012 vide its order dated 07.11.2013 and also by Hon'ble Supreme Court in Special Leave to Appeal (C) No. 4990 of 2014 vide its order dated 21.07.2014? 4. The facts in brief are that the assessee i.e. Improvement Trust, Bathinda is a Trust constituted under the Punjab Town Improvement Act, 1922 (for short '1922 Act'). Vide order