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TMI Blog2021 (9) TMI 51X X X X Extracts X X X X X X X X Extracts X X X X ..... nity only and the target group of the assessee are Safai Karmacharis , who may or may not belong to SC, ST or OBC community? - HELD THAT:- Since the Tribunal which is the highest fact finding authority has given a categorical finding, which suffers from no perversity, this Court finds no reason to interfere. Accordingly, the present appeal, being bereft of merit, is dismissed. - ITA 138/2021 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Safai Karmacharis , who may or may not belong to SC, ST or OBC community. 4. In our opinion, the Tribunal has given a categorical finding of fact that the respondent assessee, which is a Section 25 Company fully owned by the Government of India, uses its funds exclusively for the benefit of SC community who are inhabitants of Delhi. The relevant portion of the impugned order is reproduced herei ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... duled Caste, Scheduled Tribe or Other Backward Classes and also in the inhumane practice of scavenging and other sanitation activities. SafaiKaramcharis Manual Scavengers are the poorest of the poor in the society and it does not require any Certificate to know the said fact. Further, Section 10(26B) clearly says that the target group could be the members of the Schedule Castes or the Scheduled ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lso stated therein that a general agreement was on this aspect between the assessee and state agency. These circumstances do not admit of any doubt as to the entitlement of the assessee to claim the benefit under section 10(26B) and with that view of the matter we find it difficult to agree with the view of the authorities below. We, therefore, set aside both the orders and direct the Learned Asse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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