2007 (4) TMI 186

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....ed by the Income Tax Appellate Tribunal, Delhi Bench 'D' in ITA No.1731/Del/1996 relevant for the assessment year 1981-82. 2   It will be noticed immediately that the controversy in this case has been pending for the last 25 years. The matter had gone up to the Income Tax Appellate Tribunal on three occasions and it is only after the third decision rendered by the Tribunal that the ma....

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....es preferred an appeal before the Tribunal and those directions were more or less confirmed by the Tribunal. 6    In the second round, a decision was taken against the Assesses by the  Assessing Officer and the matter travelled upto the Income Tax Appellate Tribunal which disposed of the appeal and in the second order, which was passed on 21^st February, 1994 the Tribunal ca....

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.... in holding that the expenses were in connection with the charitable activities of the Assesses and, therefore, the Assesses was entitled to disallowance on this amount. 9 According to learned counsel for the Revenue when the matter was remanded back by the Commissioner of Income Tax (Appeals) in the first round itself, the Assessing Officer could have reopened the entire gamut of facts and cou....