The ITAT allowed the assessee's claim for exemption under...

The ITAT allowed the assessee's claim for exemption under section 10(23C)(v) despite the failure to file the audit report within the time prescribed under section 139(1), holding that the statutory time limit for audit report submission is not mandatory for denial of exemption. The tribunal emphasized that receipts in the form of offerings to an institution wholly dedicated to religious purposes do not constitute taxable income. The assessee, being a government-controlled entity with accounts approved by the State Assembly, was presumed to have applied the receipts appropriately. Technical non-compliance was dispensed with to uphold fairness in taxation. Consequently, the reassessment orders computing assessable income were set aside, and the exemption under section 10(23C)(v) was granted in full, directing the assessing officer to give effect accordingly.