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of The ITAT reversed the CIT(A)'s order, granting exemption u/s.10(23C)(iiiad) to the appellant educational society. The Tribunal found that despite operating nursery and primary schools from the same premises with shared staff and a common bank account, the appellant existed solely for educational purposes. Since annual income from each school was below Rs. 1 crore threshold, the appellant qualified for tax exemption. The AO had erroneously aggregated the receipts from both schools to deny exemption, and the CIT(A) incorrectly upheld this assessment based on common premises and banking arrangements. The ITAT allowed the appeal, confirming the appellant's eligibility for exemption r.w.r. 2BC of I.T. Rules, 1962.
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