Rejection of Revision application u/s 264 - Exemption u/s 11...

Rejection of Revision application u/s 264 - Exemption u/s 11 denied to assessee - benefits denied merely on the ground that the donor has deducted TDS u/s 194C and 194J while allocating requisite grants to the assessee - scope of principle of consistency in taxation matters - The High Court held that, the deduction of TDS under specific sections was deemed an insufficient basis to deny exemptions under Sections 11 and 12. The court underscored that such deductions, possibly made under a misconception by the donors, should not adversely affect the Foundation's eligibility for exemptions. - Benefit of exemption allowed.

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