Interest earned by an educational institution on unspent...

Interest earned by an educational institution on unspent Government grant funds temporarily parked in bank accounts and FDRs was treated as incidental to the grants, not as an independent source of income. On the facts that the assessee was formed solely to run an engineering college, had land allotted by the State, received funding only through Government grants and allied contributions, and had no operational income while the college was under construction, it was held to be wholly or substantially financed by Government and entitled to exemption under section 10(23C)(iiiab). As the quantum addition was deleted, the related penalty under section 270A was held purely consequential and unsustainable.

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