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2018 (10) TMI 1915 - AT - Income TaxExemption u/s 11 - proof of Charitable activity u/s 2(15) - Principle of consistency - assessee has charging fee/consideration from the activity of vocational training - as per AO activity of the assessee involves advancement of any other abject of general public utility and its receipts exceeds the mandatory limit as specified under proviso to section 2(15) - Whether CIT(A) erred in allowing the benefit of Section 11(1)(a) & 11(2) of the Act which is contrary to the provisions of section 2(15) r.w.s. 13(8) of the Act.? - CIT-A deleted the addition As no change in the facts and circumstances in the impugned case in comparison to the previous assessment years and the Revenue in earlier year has accepted the same. Therefore in our considered view the principles of consistency should be applied - see RADHASOAMI SATSANG [1991 (11) TMI 2 - SUPREME COURT] - Decided against revenue.
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