Dismissing the appeal of the revenue the Court held that, receiving grant from Government in excess of 50 Per Cent. of its total receipts can be considered as substantially financed by Government hence entitled to benefit of exemption for assessment years prior to amendment. Original assessment u/s 143(1) accordingly reassessment is held to be proper. (AY. 2004 -05, 2006-07, 2007 -08)
DIT v. Tata Institute of Social Sciences. (2019) 413 ITR 305 / 177 DTR 417/ 308 CTR 759/ 263 Taxman 387(Bom.)(HC)
S. 10(23C) : Educational institution-Wholly or substantially financed by Government -Receiving grant from Government in excess of 50 Per Cent. of its total receipts-Entitled to benefit of exemption for assessment years prior to amendment-Original assessment u/s 143(1) – Reassessment is held to be proper. [S.10(23C)(iiiab), 143(1), 147, 148]
Fine Citation