CIT (E) v. Tibetan Children’s Village Dal Lake (2023) 335 CTR 380 /155 taxmann.com 118 (Himachal Pradesh)(HC)

S. 147 : Reassessment –Change of opinion-Spent more than 85 per cent of receipts-Order of Tribunal quashing the reassessment order is affirmed.[S. 11, 12, 12A, 13, 148, 260A]

Dismissing the appeal of the Revenue the Court held that the Tribunal held that assessee had in fact spent much more than 85 per cent of its receipts under head ‘funds pending utilization’ and also of total receipts and entire spending was towards charitable purposes and there was no income accumulated or set apart in excess of 15 per cent of income during year under consideration. Order of Tribunal quashing the reassessment order is affirmed.   (AY. 2004-05, 2005-06)