https://www.taxtmi.com/caselaws?id=4477 SC held that the third proviso to s.10(23C)(vi) does not import the words "in India" for application of income, and the Prescribed Authority (PA) may, when granting approval, impose conditions (including estimated percentages of accounting income to be applied to education in India). The PA's stipulations differ from assessment-stage compliance, which must be evaluated annually. The Court set aside the CBDT order dated 12.10.2004 and remitted the matter to CBDT for fresh consideration under law, noting the applicant met the threshold requirement of actual existence as an educational institution. en-us Fri, 09 May 2008 00:00:00 +0530 Tue, 09 Sep 2025 10:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=4477 SC held that the third proviso to s.10(23C)(vi) does not import the words "in India" for application of income, and the Prescribed Authority (PA) may, when granting approval, impose conditions (including estimated percentages of accounting income to be applied to education in India). The PA's stipulations differ from assessment-stage compliance, which must be evaluated annually. The Court set aside the CBDT order dated 12.10.2004 and remitted the matter to CBDT for fresh consideration under law, noting the applicant met the threshold requirement of actual existence as an educational institution. Case-Laws Income Tax Fri, 09 May 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=4477