https://www.taxtmi.com/caselaws?id=773201 The Tribunal allowed the educational institution's appeal for AY 2012-13, granting exemption under Section 10(23C)(iiiab) despite government financing of only 31.76% of total receipts. The Tribunal held that Rule 2BBB's 50% threshold for "substantial financing" was prospective, applying only from AY 2015-16 onwards per CBDT Circular 01/2015. Following HC precedents that recognized government financing between 25-45% as substantial under the pre-amendment regime, the Tribunal concluded the institution established by State Legislature Act and existing solely for educational purposes qualified for the exemption. The assessment order denying exemption was set aside. en-us Mon, 16 Jun 2025 00:00:00 +0530 Thu, 19 Jun 2025 08:29:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773201 The Tribunal allowed the educational institution's appeal for AY 2012-13, granting exemption under Section 10(23C)(iiiab) despite government financing of only 31.76% of total receipts. The Tribunal held that Rule 2BBB's 50% threshold for "substantial financing" was prospective, applying only from AY 2015-16 onwards per CBDT Circular 01/2015. Following HC precedents that recognized government financing between 25-45% as substantial under the pre-amendment regime, the Tribunal concluded the institution established by State Legislature Act and existing solely for educational purposes qualified for the exemption. The assessment order denying exemption was set aside. Case-Laws Income Tax Mon, 16 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773201