2010 (7) TMI 1016

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....ociety. It has been provided a sum of Rs. 5,61,51,398-00 as Government grant for the assessment year 2002-03. The income from other sources is Rs. 9,79,09,465-00. The total receipt is Rs. 1540,60,863-00. The government grant constitutes 36.42% of the total receipts. Therefore the assessee claimed exemption under section 10 (23C) (iiiab). It was declined by the Assessing Authority. In Appeal the fi....

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....e purpose of profit and which is wholly and substantially financed by the government" (4) The word 'substantial' has not been defined under the Income Tax Act. However, it has been the subject matter of interpretation by various Courts in various contexts. The authorities in deciding what constitutes a 'substantial' portion of the finance have taken note of the statutory provisions contained in....

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....nd out whether the grant of 36.42% of total receipts constitutes substantial finance by the Government. (6) Viewed from that angle, after excluding fees received from the students, when we look at the amount received by way of donation from others. When compared to the amount granted by the government, the grant of 36.42% of the total revenue do constitute substantial financial aid from the gov....