2016 (11) TMI 1380

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..... commercial receipts and guided by proviso to Section 2(15) and held that the assessee could not avail the benefit under Section 11(23) of the Act. The ITAT relied upon the judgment in the case of India Trade Promotion Organisation vs Director General of Income Tax (2015 (1) TMI 928 - DELHI HIGH COURT) which had observed that that as long as the predominant activity of an institution is not busines .....

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..... 961 was not attracted so as to deny the benefit of Section 11 of the Act. The assessee was a recipient of research and training grant and other income to the tune of ₹ 1.36 crores. The Assessing Officer (AO) determined that the latter were commercial receipts and guided by proviso to Section 2(15) and held that the assessee could not avail the benefit under Section 11(23) of the Act. The .....

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