Dismissing the appeal of the Revenue the Court held that during the assessment proceedings the Assessing Officer has examined the utilisation of fund hence reopening on account of change of opinion is not permissible. Order of Tribunal is affirmed. (AY. 2004-05 to 2009-10)
CIT(E) v. Tibetan Children’s Village Dal Lake (2024)470 ITR 314 (HP)(HC)
S. 147 : Reassessment-Change of opinion-Charitable trust-Accumulation of income-Fund pending utilization-Examined in the course of regular assessment proceedings-Reassessment is bad in law. [S 11, 12(1), 13, 148, 260A]
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