2023 (3) TMI 1554

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....nding Counsel assisted by Mr. A. Kedia, Junior Standing Counsel For the Respondent : Mr. Sidhartha Ray, Senior Advocate assisted by Mr. K.K. Sahoo, Advocate ORDER I.A. No.34 of 2023 1. For the reasons stated, the I.A. is allowed. The delay in filing the appeal is condoned. ITA No.38 of 2023 2. The present appeal by the Revenue is directed against an order dated 13th September 202....

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....s students had been directly carried to the balance sheet under the nomenclature "Development Fund' instead of being routed through the income and expenditure account. This was then treated as part of the Revenue and therefore the taxable income under Section 11 (1) of the Act was taken to be Rs.51,97,46,092/-. 6. In replying to the above SCN, the Assessee gave a calculation after reducing the ....

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....umulation, without considering the capital expenditure to the tune of Rs.258crores. As noted by the ITAT, if the said bill taken into account the taxable income would be a loss. It would have been observed the 15% accumulation granted to the Assessee. Further, even after treating the development fees of Rs.111crores as revenue income, the net figure would still be a loss. 10. As noted by the IT....