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2012 (12) TMI 1011 - AT - Income TaxClaim of exemption under section 10(23C)(iiiab) - Held that:- Substantial part did not connote an idea of being a major part i.e. more than 50%, in which in the context of section 2(22)(e)(ii)) it was held that in case 40% of assets were deployed by way of loans and advances then the business of money lending has to be considered as substantial part of the business of the assessee. CIT(A) also relied on the judgment in the case of Indian Institute of Management (2010 (8) TMI 890 - KARNATAKA HIGH COURT), in which it was held that when 37.85% of total income was financed by Central Government it had to be considered as substantially financed by the government. In case of the assessee 57.46% of gross receipts is financed by the government. Further in the earlier orders similar financing by the government had been considered as substantially financed and exemption allowed to the assessee. We, therefore see no infirmity in the order of CIT(A) in allowing the claim of the assessee
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