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The High Court of Allahabad ruled in favor of the assessee, a charitable institution, stating that its income should not be taxed under sections 12 and 13 of the Income-tax Act, 1961. The court also held that the assessment itself was invalid, and interest charged for non-payment of tax was deemed incorrect. The Tribunal's decision was upheld, and the reference was answered in favor of the assessee and against the Revenue.
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