invited to the decision of the Supreme Court in the case of
Radhasoami Satsang vs. CIT : 193 ITR 321, wherein it has been held that ... apply the decision of the Supreme Court in the case of
Radhasoami Satsang (supra), observing that in the said decision the Court applied principle
principle of consistency, the Ld. AR relied upon the
following judicial pronouncement:
Radhasoami Satsang v. CIT [1992] 60 Taxman 248 (SC)
13. We are aware ... Tribunal was justified in holding that the income derived by the
Radhasoami Satsang was entitled to exemption under sections 11 and 12 .
(Emphasis Supplied
decision of the
Hon'ble Supreme Court in the case of Radhasoami Satsang Vs. CIT
[193 ITR 321 (SC)]. Not convinced with the submission ... decision of the Hon'ble
Supreme Court in the case of Radhasoami Satsang Vs. CIT (supra)
and the decision in the case
does apply. In support he placed reliance on the following decisions:
i)Radhasoami Satsang Vs CIT 193 ITR 321 (SC))
ii)DIT(E) Vs Guru
Goodyear India Ltd., Faridabad vs Dcit, Circle-10(1), New Delhi on 26 July, 2024
Goodyear India Ltd, Faridabad vs Acit, Circle-10(1), New Delhi on 26 July, 2024
held by
Hon'ble Apex Court as under:
"25. In Radhasoami Satsang v. CIT this Court did not think it
appropriate to allow ... interesting passage
from Hoystead v. Taxation Commr., wherein it was said:
( Radhasoami Satsang case, SCC pp. 665-66, para 14)
"14. ... Parties
held by
Hon'ble Apex Court as under:
"25. In Radhasoami Satsang v. CIT this Court did not think it
appropriate to allow ... interesting passage
from Hoystead v. Taxation Commr., wherein it was said:
( Radhasoami Satsang case, SCC pp. 665-66, para 14)
"14. ... Parties
held by
Hon'ble Apex Court as under:
"25. In Radhasoami Satsang v. CIT this Court did not think it
appropriate to allow ... interesting passage
from Hoystead v. Taxation Commr., wherein it was said:
( Radhasoami Satsang case, SCC pp. 665-66, para 14)
"14. ... Parties
2012
Member Judge Bench of the Supreme Court in the case of
Radhasoami Satsangl vs. CIT 193 ITR 321(SC), wherein it
had been held ... consistency" must be
followed by tax authorities. But even in Radhasoami
Satsang case, the Hon'ble Supreme Court had categorically
mentioned that
