https://www.taxtmi.com/caselaws?id=760676 ITAT Ahmedabad allowed the assessee's appeal and quashed the CIT(E)'s order under Section 263. The tribunal held that the AO's decision to grant exemption under Section 10(23C)(iiiab) for AY 2014-15 was neither erroneous nor prejudicial to revenue. The AO correctly included interest income on government grants in calculating the 50% substantial financing threshold and properly did not apply Rule 2BBB retrospectively, as it was introduced only from AY 2015-16. The CIT(E) erred in excluding interest income and attempting retrospective application of Rule 2BBB. en-us Tue, 22 Oct 2024 00:00:00 +0530 Fri, 25 Oct 2024 08:10:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760676 ITAT Ahmedabad allowed the assessee's appeal and quashed the CIT(E)'s order under Section 263. The tribunal held that the AO's decision to grant exemption under Section 10(23C)(iiiab) for AY 2014-15 was neither erroneous nor prejudicial to revenue. The AO correctly included interest income on government grants in calculating the 50% substantial financing threshold and properly did not apply Rule 2BBB retrospectively, as it was introduced only from AY 2015-16. The CIT(E) erred in excluding interest income and attempting retrospective application of Rule 2BBB. Case-Laws Income Tax Tue, 22 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760676