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    <title>2024 (10) TMI 1275 - ITAT AHMEDABAD</title>
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    <description>Revision under section 263 was not justified where the Assessing Officer had examined the exemption claim under section 10(23C)(iiiab) and adopted a legally tenable view based on the institution&#039;s financing pattern. Interest earned on government grants was treated as part of the grant for determining substantial Government financing, and Rule 2BBB could not be applied retrospectively to the year in question. On these facts, the assessment was neither erroneous nor prejudicial to the interests of Revenue, so the revisionary order was quashed and the exemption claim was upheld.</description>
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      <description>Revision under section 263 was not justified where the Assessing Officer had examined the exemption claim under section 10(23C)(iiiab) and adopted a legally tenable view based on the institution&#039;s financing pattern. Interest earned on government grants was treated as part of the grant for determining substantial Government financing, and Rule 2BBB could not be applied retrospectively to the year in question. On these facts, the assessment was neither erroneous nor prejudicial to the interests of Revenue, so the revisionary order was quashed and the exemption claim was upheld.</description>
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