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of Exemption u/s 11 and 12 - if there is any infirmity in the grant of certificate issued u/s 80G then it is for the Department to look into that aspect otherwise it has no relevance or bearing in interpreting whether subsection (2) of section 115BBC is applicable in this case or not. Otherwise also, similar donations have been accepted not only in the earlier years but also in the subsequent years u/s 143(3) and it has been categorically found that provisions of section 115BBC is not applicable, therefore, in view of the rule of consistency, such donations cannot be disallowed. - AT
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