https://www.taxtmi.com/caselaws?id=450689 The ITAT Cochin addressed a rectification application under section 154 where the AO disallowed exemption under section 11 due to the assessee's non-registration under section 12AA. The assessee claimed alternative exemption under section 10(23C)(iiiad) as an educational institution. The ITAT held that voluntary contributions constitute income by definition under section 2(24)(iia), though exempt under section 11(1)(d). The tribunal distinguished between "annual receipts" and "gross receipts" for threshold determination, noting corpus donations are uncertain and not part of regular annual receipts. The ITAT allowed the alternative claim under section 10(23C)(iiiad), directing deletion of its disallowance, emphasizing reasonable interpretation of tax laws in consonance with justice. en-us Thu, 07 Mar 2024 00:00:00 +0530 Wed, 04 Dec 2024 13:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450689 The ITAT Cochin addressed a rectification application under section 154 where the AO disallowed exemption under section 11 due to the assessee's non-registration under section 12AA. The assessee claimed alternative exemption under section 10(23C)(iiiad) as an educational institution. The ITAT held that voluntary contributions constitute income by definition under section 2(24)(iia), though exempt under section 11(1)(d). The tribunal distinguished between "annual receipts" and "gross receipts" for threshold determination, noting corpus donations are uncertain and not part of regular annual receipts. The ITAT allowed the alternative claim under section 10(23C)(iiiad), directing deletion of its disallowance, emphasizing reasonable interpretation of tax laws in consonance with justice. Case-Laws Income Tax Thu, 07 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450689