2010 (7) TMI 1016

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..... or the assessment year 2002-03. The income from other sources is ₹ 9,79,09,465-00. The total receipt is ₹ 1540,60,863-00. The government grant constitutes 36.42% of the total receipts. Therefore the assessee claimed exemption under section 10 (23C) (iiiab). It was declined by the Assessing Authority. In Appeal the first appellate authority granted exemption, which order was affirmed by .....

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..... by the government (4) The word substantial has not been defined under the Income Tax Act. However, it has been the subject matter of interpretation by various Courts in various contexts. The authorities in deciding what constitutes a substantial portion of the finance have taken note of the statutory provisions contained in the Banking Regulation Act, 1949. Where, a person who has the b .....

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..... es substantial finance by the Government. (6) Viewed from that angle, after excluding fees received from the students, when we look at the amount received by way of donation from others. When compared to the amount granted by the government, the grant of 36.42% of the total revenue do constitute substantial financial aid from the government and thus the institution-assessee is entitled to the .....

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