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2019 (9) TMI 1502

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..... TA Nos.196 & 197/17-18 dated 28.02.2019 for assessment years 2010-11 & 2011-12. ITA No.1835/Chny/2019 is an appeal filed by the Revenue and C.O No.83 /Chny/2019 is Cross-Objections filed by the assessee against the Order of the Commissioner of Income Tax (Appeals)- 10, Chennai, in ITA Nos.198/17-18/C.I.T(A)-10(Tr.) dated 28.02.2019 for assessment year 2015-16. Since common issue arises for consideration in all these appeals and Cross objections, all these appeals of Revenue and C.O. filed by the assessee are disposed of by this common order. 2. Mr.S.Bharath represented on behalf of the Revenue and Mr.S.Bhaskar represented on behalf of the Assessee. 3. The Revenue has raised the following common grounds in all these three appeals for our c .....

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..... 2309/Mds/2005 vide order dated 26.05.2006 and for the assessment years 2012- 13 to 2014-15 in ITA Nos.2896 to 2898/Mds/2017 vide order dated 26.04.2018. It was further submitted that ld.CIT(A) had followed the judicial discipline by following decisions of the Co-ordinate Bench of this Tribunal in assessee's own case for the assessment year 1997-98 and for the assessment years 2012-13 to 2014-15 (supra). It was submitted that the only issue in these appeals was against the action of ld.CIT(A) granting exemption u/s.10(21) of the Act. 5. In reply, ld.DR strongly supported the order of the Assessing Officer. 6. We have heard the rival contentions and perused the material available on record. The primary order of the Tribunal in assessee's ow .....

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..... gents which can alleviate the possible toxicological manifestations caused by chemical pesticides. 6. To conduct basis research studies to develop, characterize and test in vitro cell line models to assess toxicity of environmental agents. 7. To establish and conduct non-clinical safety assessment of environmental agents under the principles of Good Laboratory Practices (GLP)" The 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 .....

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