The only issue involved is whether the adjustment can be done u/s 143(1), only on the basis of approval received u/s 10(23C)(i) r.w.s. 10(23C)(vi) but in the absence of approval u/s 12A. It was held that, in principle, the findings of the Commissioner (Appeals) in the impugned order were well-reasoned. But the anomaly arose after the approval u/s 10(23C)(i) r.w.s. 10(23C)(vi) was received, as the assessee’s entire income having derived from the educational institution, was fully exempted even after the said adjustment, as the tax cannot be levied on the exempted income. In such facts and circumstances, the matter was restored back to the AO to give effect to the order passed u/s 10(23C)(i) r.w.s. 10(23C)(vi) for the relevant year as the assessee was entitled to claim exemption u/s 10(23C). Therefore, the AO was directed to allow the benefit of S. 10(23C) and allow consequential relief to the assessee. (AY. 2022-23)