2007 (1) TMI 102

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....4, passed by the Income-tax Appellate Tribunal, Delhi Bench "C" in I. T. A. Nos. 4497 and 4498/Del/2000 relevant for the assessment years 1996-97 and 1997-98. 2 The only question that arises is whether the assessee is entitled to the benefit of sections 10(22A) and 11 of the Income-tax Act, 1961. 3 Learned counsel for the Revenue has taken us through the assessment order. It appears that the....

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....f Income-tax (Appeals). The Revenue appealed against the order passed by the Commissioner of Income-tax (Appeals) and that appeal was dismissed by the Tribunal which has given rise to the present appeal under section 260A of the Act. 6 Learned counsel for the assessee has brought to our notice that from the assessment years 1988-89 to 1994-95 there was no change in the facts and throughout this....

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....ted the order passed by the Tribunal and did not challenge it any further 8 Thereafter, for the assessment year 1998-99 the Assessing Officer again denied the exemption to the assessee and that view was upset by the Tribunal. Against the order passed by the Tribunal for that assessment year, that is, 1998-99, the Revenue preferred an appeal which we have dismissed today since no substantial que....

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.... 12 The agreements dated April 1, 1989 were subsisting and the activities of 12 the assessee had remained the same. The only change that has occurred is that the Assessing Officer had earlier granted the exemption to the assessee but for some reason he has now decided to deny the exemption to the assessee. 13 The Tribunal has consistently taken the view that the assessee is entitled to exempti....