CIT(E) v. Swami Ganga Giri Janta Girls College (2024)466 ITR 393 /162 taxmann.com 677 (P&H)(HC)

S. 10 (23C): Educational institution-Solely for educational purposes and not for profit-Substantial grant of finance from Government-Order of Tribunal is affirmed.[S. 10(23C)(iiib), 11, 260A, R. 2BBBB.]

Dismissing the appeal of the Revenue the Court held  that since the Assessing Officer in his order had reached the conclusion that the assessee had claimed exemptions under section 10(23C)(iiiab) since it was substantially financed by the Government of more than 20 per cent., and expenditure had been incurred by the assessee towards its aims and objects in carrying out educational activities alone, the exemptions were rightly granted. The Tribunal had found that rule 2BBB of the Income-tax Rules, 1962 was not applicable during the assessment year 2012-13, since it came into force with effect from December 12, 2014. There was no error in the orders passed by the Tribunal and the Assessing Officer and, therefore, need not be interfered with. No substantial question of law. (AY.2012-13)