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HC held that the notice u/s 143(2) served on 1-10-2012 was valid, as it was within the prescribed six-month period considering Section 10 of the General Clauses Act. Regarding charitable purpose exemption u/s 11 and 2(15), the Court found that the trust's primary objective was charitable, with Dharamshala rentals conducted on a cost basis. The Court ruled in favor of the assessee, rejecting revenue's contention of commercial activities, and directed allowance of depreciation. The appellate authorities' findings were deemed legally incorrect, with the substantial question answered in the assessee's favor, thereby preserving the trust's charitable status and tax exemption.
HC held that the notice u/s 143(2) served on 1-10-2012 was valid, as it was within the prescribed six-month period considering Section 10 of the General Clauses Act. Regarding charitable purpose exemption u/s 11 and 2(15), the Court found that the trust's primary objective was charitable, with Dharamshala rentals conducted on a cost basis. The Court ruled in favor of the assessee, rejecting revenue's contention of commercial activities, and directed allowance of depreciation. The appellate authorities' findings were deemed legally incorrect, with the substantial question answered in the assessee's favor, thereby preserving the trust's charitable status and tax exemption.
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