PRATHYUSHA EDUCATIONAL TRUST Vs. PRINCIPAL COMMISSIONER OF INCOME

JUDGEMENT

(1.) These Tax Case Appeals filed by the assessee under Section 260A of the Income Tax Act, 1961 (for brevity 'the Act') are directed against the common order dated 27.05.2019 in I.T.A.Nos.637, 638 and 370/CHNY/2017 for the assessment years 2010-2011 and 2011-2012.

(2.) I.T.A.Nos.637 and 638/CHNY/2017 are appeals filed challenging the common order passed by the Commissioner of Income Tax (Appeals) (CIT(A)) dated 12.01.2017 who had confirmed the assessment order passed by the Assistant Commissioner of Income Tax, Central Circle-II(3), Chennai dated 28.03.2013 for both the assessment years. I.T.A.No.370/CHNY/2017 was filed challenging the order passed by the Principal Commissioner of Income Tax, Central-II, Chennai dated 07.12.2016 under Section 12AA(3) of the Act, whereby the registration granted to the assessee Trust under Section 12AA vide order dated 22.10.2002 passed by the Director of Income Tax (Exemption), Chennai was cancelled with effect from 01.04.2009, i.e. from the assessment year 2010-2011 onwards. To be noted that an order dated 18.11.2014 passed by the Director General of Income Tax (Investigation), Tamil Nadu and Puducherry withdrawing the exemption under Section 10(23C)(vi) from the assessment year 2010-2011 onwards had not been challenged by the appellant assessee by way of any independent proceedings.

(3.) These appeals have been filed raising the following substantial questions of law: