2020 (5) TMI 336

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....ivasan, Addl. CIT ORDER PER N.R.S. GANESAN, JUDICIAL MEMBER: All the five appeals of the assessee are directed against the orders passed by the Commissioner of Income Tax (Appeals), Salem dated 24.10.2018 & 29.10.2018 and pertains to the assessment years (AYs) 2010-11 to 2014-15. ITA No.78/Chny/2019 for Assessment Year 2010-11: 2. Shri G.Baskar, the Ld. Counsel for the assessee submitted ....

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....utory limit of four years goes to the root of the matter, therefore it is not necessary either for the assessee or to the Department to raise the issue before this Tribunal. Even though there was no necessity for raising this issue of limitation, this Tribunal is expected to record a finding whether the assessment was reopened within the period of limitation. In this case, the assessee has taken a....

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.... ITA No.79/Chnhy/2019 for Assessment year 2011-12 Shri G. Baskar, the Ld. Counsel for the assessee submitted that the assessment was reopened within four years. The return was processed u/s. 143(1) of the Act and there was no order u/s. 143(3) of the Act. Referring to the merit of the case, the Ld. Counsel for the assessee submitted that the assessee is running Kalyana Mandapam. One of the objects....

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....asan, the Ld. Departmental Representative submitted that the main object of the assessee's Trust is running Kalyana Mandapam, which cannot not be construed as charitable activity. Therefore, the assessee is not eligible for exemption u/s. 11 of the Act. Referring to s. 11(6) of the Act, the Ld. Counsel submitted that the Supreme Court held that this provision is prospective in nature therefore, no....