2020 (5) TMI 336

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.... for Assessment Year 2010-11: 2. Shri G.Baskar, the Ld. Counsel for the assessee submitted that the Assessing Officer reopened assessment beyond the statutory period of four years. There is not even whisper in the assessment order that there was negligence on the part of the assessee in disclosing the entire details for the assessment. Therefore, the reopening of the complete assessment beyond the period of four years is not justified. 3. On the contrary, Shri A.R.V. Sreenivasan, the Ld. Departmental Representative submitted that the assessee has not raised that the issue of limitation in reopening the assessment either before the AO or before the Ld. CIT(A) and he has no records to argue the case. 4. Having heard the Ld. Counsel f....

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....n 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 of the assessee is to establish and maintain Kalyana Mandapam apart from other objects including establishing and maintenance of cremation ground, donations to the students, recreation etc. On a query from the Bench how running a Kalyana Mandapam would be a charitable activity u/s. 2(15) of the Act, the Ld. Counsel for the assessee submitted that the assessee charging very nominal amount from the general public, therefore, it has to be considered as charitable activity. Referring to the issu....