https://www.taxtmi.com/caselaws?id=448568 ITAT Kolkata quashed CIT(E)'s revision order u/s 263 regarding trust's rental income exemption u/s 10(23C)(vi). Educational society with 1500 students rented vacant buildings during decreased enrollment to cover fixed expenses. CIT(E) argued rental income wasn't from educational activity, making AO's exemption order erroneous. ITAT held buildings were constructed from educational funds, rental was for society's educational objectives, and AO correctly relied on jurisdictional HC precedent in Sahu Jain Trust. Since SC's restrictive New Noble Educational Society judgment applied only from 19/10/2022 onwards, earlier favorable interpretation remained valid. AO's assessment order restored, revision quashed in assessee's favor. en-us Fri, 01 Dec 2023 00:00:00 +0530 Sat, 20 Jan 2024 10:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448568 ITAT Kolkata quashed CIT(E)'s revision order u/s 263 regarding trust's rental income exemption u/s 10(23C)(vi). Educational society with 1500 students rented vacant buildings during decreased enrollment to cover fixed expenses. CIT(E) argued rental income wasn't from educational activity, making AO's exemption order erroneous. ITAT held buildings were constructed from educational funds, rental was for society's educational objectives, and AO correctly relied on jurisdictional HC precedent in Sahu Jain Trust. Since SC's restrictive New Noble Educational Society judgment applied only from 19/10/2022 onwards, earlier favorable interpretation remained valid. AO's assessment order restored, revision quashed in assessee's favor. Case-Laws Income Tax Fri, 01 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448568