Assessee Denied Section 10(21) Tax Benefits Due to Classification as Institution by AO and DITE Approval.

Exemption u/s 10(21) - AO treated the assessee as an institution while granting approval under Section 35(1)(ii) by the competent authority as well as by the Directorate of Income Tax (Exemption) (DITE) and not as an association and therefore, the assessee cannot claim the benefit under Section 10(21) of the Act. - The above submission cannot be countenanced for more than one reason. - HC .....

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