reassessment framed on such an incorrect foundation is illegal, void ab initio, and without jurisdiction. 3. The Ld. Commissioner of Income Tax (Appeals) failed to appreciate that the appellant, being a temple governed by the Endowments Department of the Government of Andhra Pradesh, is eligible for exemption u/s 10(23BBA) 3 Sri Koti Linga Hari Hara Mahakshetram Temple