CIT (E). v Institute of Liver and Biliary Sciences (2025) 482 ITR 1004 (Delhi)(HC)

S. 10 (23C): Educational institution-Hospital or medical institution Grand-in-aid from Government Effect of section 10(23C) (iiiac)-Interest on grants-in-aid-To be added to grants-in-aid or returned to Government-Interest entitled to exemption [S. 10(23C) (iiiac).]

Held, dismissing the appeal, that the issue raised was for the assessment year 2013-2014. Upon reading the provisions of section 10(23C)(iiiac) of the Act and rule 2BBB of the Income-tax Rules, 1962 it was clear that in the given period, the Government had to either directly fund the concerned hospital or institute or seek adjustment by factoring in the interest earned on previous grants. In case there was no adjustment, the interest, would have to be returned to the concerned Government for being credited to the Consolidated Fund of India. That being the position, no interference was called for with the order. No substantial question of law arose for consideration. Finance (No. 2) Act, 2014, with effect from April 1, 2015 ((2014) 366 ITR (St) 21).

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