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    <title>2026 (6) TMI 200 - ITAT MUMBAI</title>
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    <description>Section 10(46) exemption turns on the nature and source of the receipt, not merely on when it is recognised in the books. Prior period licence fees, advances and other regulatory receipts were treated as exempt because they arose from statutory functions and their character was undisputed, so accounting as prior period income did not change their exempt status. Similar treatment was given to ancillary receipts, including interest on staff welfare loans, personal use of office vehicle income, miscellaneous income and interest on loans to others, because they were incidental and non-commercial, and later notification coverage supported their character as specified income.</description>
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