THE COMMISSIONER OF INCOME TAX Vs. THE RESEARCH INSTITUTE OF CIVIL HEALTH AND INTEGRATION (RINCHI), THROUGH ITS CHAIRMAN

JUDGEMENT

(1.) HEARD learned Counsel for the parties.

(2.) THE following substantial question of law is involved in this appeal.:

(3.) WE need not to give details of the reasons given in the order dated 23.06.2008 but it appears from the order dated 13.02.2009 passed by the I.T.A.T. that even after recording of the contentions of the parties the I.T.A.T. proceeded to decide the matter only on one point that there is no change in circumstance without reversing any of the findings recorded by the authority concerned who passed the order of cancellation of the registration of the trust of the Respondents and then relied upon the judgment of the Hon'ble Delhi High Court quoted in para -5 which has been delivered in a matter where it has been held that mere change in opinion will not empower the assessing authority to pick and choose the assessment year in which an appeal should have been filed and this judgment has no relevance so far as the present controversy is concerned except that there is a principle of law that mere change in opinion of authorities subsequent will not give him some powers under certain provisions of law.