DIRECTOR OF INCOME TAX Vs. DALMIA SHIKSHA PRATHISHTHAN

JUDGEMENT

(1.) THE Revenue is aggrieved by an order dated 20th February, 2006 passed by the Income Tax Appellate Tribunal, Delhi Bench A, in ITA No. 1059/del/2002 relevant for the Assessment Year 1997-98.

(2.) THE Assessee is a trust imparting education through four educational institutions in Orissa and Rajasthan. It is registered under Section 12a (a) of the Income Tax Act, 1961 (the Act) since 1985. Upto and including the assessment Year 1996-97, the Assessee was allowed exemption under Section 10 (22)of the Act but for the Assessment Year 1997-98, the Assessing Officer departed from the past stand despite the contention of the Assessee that there was no change in its activities, mode of investment or functioning.

(3.) THE Assessing Officer took three factors into consideration for deciding against the Assessee, namely,