https://www.taxtmi.com/caselaws?id=783189 ITAT allowed the assessee-educational trust's appeal, holding that an additional claim for exemption under s.10(23C)(iiiad) can validly be raised for the first time in appellate proceedings. ITAT clarified that the decision in Goetze (India) Ltd. restricts the AO, not the appellate authority, and found that CIT(A) had misinterpreted the ratio. It was held that registration of the trust is not a pre-condition to claim exemption where educational receipts do not exceed Rs. 1 crore, in consonance with s.10(23C)(iiiad). Consequently, ITAT set aside the order of CIT(A) and directed the AO to delete the addition. The alternative contention regarding taxation of net income was left unadjudicated. en-us Fri, 28 Nov 2025 00:00:00 +0530 Thu, 11 Dec 2025 11:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783189 ITAT allowed the assessee-educational trust's appeal, holding that an additional claim for exemption under s.10(23C)(iiiad) can validly be raised for the first time in appellate proceedings. ITAT clarified that the decision in Goetze (India) Ltd. restricts the AO, not the appellate authority, and found that CIT(A) had misinterpreted the ratio. It was held that registration of the trust is not a pre-condition to claim exemption where educational receipts do not exceed Rs. 1 crore, in consonance with s.10(23C)(iiiad). Consequently, ITAT set aside the order of CIT(A) and directed the AO to delete the addition. The alternative contention regarding taxation of net income was left unadjudicated. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783189