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TMI Blog2022 (3) TMI 1497X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Revenue and therefore the taxable income u/s 11 (1) - HELD THAT:- CIT (E) simply stated that the impugned assessment order was erroneous and prejudicial in the interest of Revenue. ITAT has in the impugned order discussed in detail the explanation offered by the Assessee regarding application of funds. Inter alia, it was noticed that CIT (E) had taken the total revenue earned, granted ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - CHIEF JUSTICE DR. S. MURALIDHAR AND JUSTICE M.S. RAMAN, MEMBER For the Appellant : Mr. R. Chimanka, Senior Standing Counsel assisted by Mr. A. Kedia, Junior Standing Counsel For the Respondent : Mr. Sidhartha Ray, Senior Advocate assisted by Mr. K.K. Sahoo, Advocate ORDER I.A. No.34 of 2023 1. For the reasons stated, the I.A. is allowed. The delay in filing the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e notice (SCN) to the Assessee under Section 263 of the Act stating that a sum of Rs.1,11,54,33,001/- collected as development fees from its students had been directly carried to the balance sheet under the nomenclature Development Fund instead of being routed through the income and expenditure account. This was then treated as part of the Revenue and therefore the taxable income under Section 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the Assessee regarding application of funds. Inter alia, it was noticed that CIT (E) had taken the total revenue earned, granted 15% accumulation, without considering the capital expenditure to the tune of Rs.258crores. As noted by the ITAT, if the said bill taken into account the taxable income would be a loss. It would have been observed the 15% accumulation granted to the Assessee. Further, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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