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2018 (5) TMI 1843 - PUNJAB AND HARYANA HIGH COURTGrant exemption u/s 10(23C)(vi) - CIT(E) declined to grant registration under Section 10(23C)(vi)by holding that no evidence of accumulation of income after following the due process had been adduced - Tribunal directed CIT(E) to grant exemption under Section 10(23C)(vi) from the date of application - HELD THAT:- Excess accumulation has to be applied for the objects of the society and if the percentage of income applied for educational purpose is less than the limit prescribed under Clause (a) of third proviso to Section 10(23C) then the exemption can be declined. In the present case, the amount of receipt during the assessment years in question exceeded more than ₹ 1 crore. The assessee utilized the amount for purchase of land for further extension of school building, which was for educational purpose only. Thus, the exemption under Section 10(23C)(vi) of the Act was rightly granted to the assessee. - Decided in favour of assessee.
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