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2019 (9) TMI 1502 - AT - Income TaxEligibility of exemption u/s.10(21) - CIT-A categorizing the “Institution” as “Association” - HELD THAT:- The primary order of the Tribunal in assessee’s own case for the assessment year 1997-98 denial of exemption by the Assessing Officer is based on the fact that the Assessee is classified as an Institution. It is the case of the Department that the Assessee-society is classified as an Institution and not as an Association and as per the provisions of sec.10(21) of the Act, exemption is available only to an Association. But once the fact that the Assessee-society is engaged in research work regarding agriculture related activities and it is recognized as a leading National Body in the field of Research in Bio-Technology and Toxicology. Further, the Central Board of Direct Taxes has classified the Assessee-society as an Association in the year 1997, after due verification of its object as well as its activities and there is no change in the objectives of the Assessee-society from its inception till date. In view of these facts and circumstances of the case and respectfully following the Tribunals decision cited supra, we hold that the Assessee is entitled to exemption under sec.10(21) of the Act as the Assessee-society is engaged in research work in agriculture related activities.
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