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The HC dismissed the Revenue's challenge and upheld the CIT(A) and ITAT orders permitting the assessee's exemptions. The court held that the assessee, constituted under a historic trust and operating through a charitable SPV, is entitled to exemption under s.10(23C)(iv) notwithstanding the AO's addition under ss.11-12 and the application of ss.13(2)(b)/13(3)(b). Applying the rule of consistency, the HC found no change in law or material facts to justify departing from earlier grants of exemption in preceding assessment years and concluded no private benefit to trustees or individuals arose. The Revenue's appeal was therefore rejected and the exemption for the relevant AY was sustained.
The HC dismissed the Revenue's challenge and upheld the CIT(A) and ITAT orders permitting the assessee's exemptions. The court held that the assessee, constituted under a historic trust and operating through a charitable SPV, is entitled to exemption under s.10(23C)(iv) notwithstanding the AO's addition under ss.11-12 and the application of ss.13(2)(b)/13(3)(b). Applying the rule of consistency, the HC found no change in law or material facts to justify departing from earlier grants of exemption in preceding assessment years and concluded no private benefit to trustees or individuals arose. The Revenue's appeal was therefore rejected and the exemption for the relevant AY was sustained.
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