CIT (E) v. Institute of Liver & Biliary Sciences (2023) 335 CTR 922 / 154 taxmann.com 401 (Delhi) (HC)

S. 10 (23C): Educational institution-Interest earned on grants-Quantifying amount of grant-in-aid-Eligible to claim exemption. [10(23C) (iiiac), 11, 13, R. 2BBB]

Dismissing the appeal of the Revenue  the Court held that if interest was included, then, grant-in-aid provided to assessee was more than 50 per cent of total receipts, the assessee is  entitle to  exemption under section 10(23C)(iiiac). Explanation appended to section 10(23C)(iiiac) providing threshold of grants received at 50 per cent was inserted via Finance Act 25 of 2014, with effect from 1-4-2015 which would not be applicable to relevant year 2013-14. (AY. 2013-14)