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As per the case facts, the revenue sought clarification of a previous Supreme Court judgment concerning the interpretation of Section 2(15) of the Income Tax Act, 1961, particularly regarding charitable
...trusts engaged in activities of general public utility. The clarification was sought to enable the Revenue to re-assess past assessments and examine eligibility on a yearly basis for the future in accordance with the judgment. The question arose as to the scope and future application of the law declared in the Supreme Court's previous judgment, specifically whether it allowed the Revenue to redo assessments for past years and examine eligibility annually for future years. Finally, the Supreme Court clarified that its previous judgment applied to the assessment years before it and were decided, with appeals decided against the revenue being final. The reference to future application meant that for assessment years not directly decided by the Court, the concerned authorities would apply the declared law based on the facts of each such assessment year. The Court found no further clarification necessary and disposed of the application in these terms.
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