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Exemption claim u/s 10(46) requires substantive conditions, including being a "notified" authority. The assessee has not been notified u/s 10(46)(c), which is the precise reason for the Assessing Officer and NFAC to decline the exemption claim. The factual position remains unchanged before the tribunal. The assessee has filed writ petitions before the jurisdictional High Court, which are pending adjudication. However, the tribunal is not a party to these proceedings, and there is no stay order against it. Consequently, the tribunal finds no reason to disturb the lower authorities' findings declining the assessee's section 10(46) exemption claim due to the lack of statutory notification.
Exemption claim u/s 10(46) requires substantive conditions, including being a "notified" authority. The assessee has not been notified u/s 10(46)(c), which is the precise reason for the Assessing Officer and NFAC to decline the exemption claim. The factual position remains unchanged before the tribunal. The assessee has filed writ petitions before the jurisdictional High Court, which are pending adjudication. However, the tribunal is not a party to these proceedings, and there is no stay order against it. Consequently, the tribunal finds no reason to disturb the lower authorities' findings declining the assessee's section 10(46) exemption claim due to the lack of statutory notification.
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