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2022 Supreme(SC) 1114

UDAY UMESH LALIT, PAMIDIGHANTAM SRI NARASIMHA, S. RAVINDRA BHAT
Assistant Commissioner of Income Tax (Exemptions) – Appellant
Versus
Ahmedabad Urban Development Authority – Respondent


Advocates appeared:
For the Petitioner(s): Mr. N. Venkataraman, ASG Mr. Rupesh Kumar, Adv. Mr. V.Chandrashekhar Bharati, Adv. Ms. Gargi Khanna, Adv. Ms. Alka Agarqwa,, Adv. Mr. Raj Bahadur Yadav, AOR
For the Respondent(s): Mr. Saurabh Soparkar, Sr. Adv. Ms. Deepanwita Priyanka, AOR

ORDER :

1. By this application, the revenue seeks a clarification of the judgment dated 19.10.2022, delivered by this court, in C.A. No. 21762/2017 and connected appeals. The clarification sought is that Para 254 of the judgment should be such as to “enable the Revenue to redo the assessments in accordance with the above judgments for the past and examine the eligibility on a yearly basis for the future and thus render justice.”

2. This court, by the judgment in question, had considered and pronounced upon the interpretation of Section 2 (15) of the Income Tax Act, 1961, in relation to charitable trusts which engage in activities that further objects of general public utility. The activities and cases of various kinds of charities, trusts and organizations, including statutory corporations and bodies, regulatory bodies, non-statutory regulatory bodies, trade organizations and bodies, sports bodies and organizations, trusts, etc were considered by the court, and dealt with in the judgment. Para 253 recorded the court’s summary of conclusions in relation to each such trust, charity or organization.

3. It was urged on behalf of the revenue, that the clarification it seeks is necessary, b


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