Bishnupur Public Education Institute v. CIT (E) (2022) 195 ITD 123 / 95 ITR 95 (SN) (Kol.)(Trib.)

S. 10 (23C) : Educational institution-Application was barred by limitation-No statutory provision too condone delay-Order of rejection was affirmed. [S. 10(23C)(vi)]

Assessee filed applications under section 10(23C)(vi) for a grant of approval as an Educational Institution.   Commissioner (E) rejected these applications were time-barred and there is no statutory provision nor there is any power to condone the delay after considering reasonable reasons. On appeal, the Tribunal held that a reasonable cause can be taken into cognizance for the condoning delay if such provision is provided in Act while considering any issue for adjudication. Order of CIT(E) rejecting the application was affirmed.  (AY. 2016-17, 2017-18, 2018-19)