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Section 10(23C) exemption for the relevant year did not require...

Return filing was not a condition for section 10(23C) exemption in the relevant assessment year.

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Income Tax September 15, 2026 Case Laws AT
Section 10(23C) exemption for the relevant year did not require return filing by entities outside the categories expressly covered by the Twentieth Proviso. A later amendment imposing a return-filing condition for specified entities could not be applied to that year. Where the revenue authorities did not find that the substantive exemption conditions were unmet, non-filing of a return alone could not defeat the claim. Exemption was consequently directed to be granted in accordance with law, and the income assessed under "Income from Other Sources" was deleted.

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Acts Income Tax