TaxTMI 
TaxTMI 
2010 (7) TMI 1016
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.... of ₹ 5,61,51,398-00 as Government grant for the assessment year 2002-03. The income from other sources is ₹ 9,79,09,465-00. The total receipt is ₹ 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 first appellate authorit....
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....h 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 the Banking Regulation Act, 1....
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....2% 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 government and thus the institution-a....