Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
ITAT ruled that interest earned on fixed deposits from unspent government grants qualifies as grant income under section 10(23C)(iiiac). When this interest is added to direct grants received, total government funding exceeds the required 50% threshold. The institution, managed by state government, meets eligibility criteria for tax exemption. ITAT upheld CIT(A)'s decision that the assessee qualifies for exemption under both section 10(23C)(iiiac) and section 11(2) of Income Tax Act. Revenue's objections were dismissed, confirming the educational institution's exempt status based on combined grant receipts and associated interest income meeting statutory requirements for substantial government funding.
ITAT ruled that interest earned on fixed deposits from unspent government grants qualifies as grant income under section 10(23C)(iiiac). When this interest is added to direct grants received, total government funding exceeds the required 50% threshold. The institution, managed by state government, meets eligibility criteria for tax exemption. ITAT upheld CIT(A)'s decision that the assessee qualifies for exemption under both section 10(23C)(iiiac) and section 11(2) of Income Tax Act. Revenue's objections were dismissed, confirming the educational institution's exempt status based on combined grant receipts and associated interest income meeting statutory requirements for substantial government funding.
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