2023 (5) TMI 633

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....appeal: "1. On the facts and circumstances prevailing in the case and as per provisions & scheme of the Income-tax Act, 1961 ('The Act') it be held that rectification order passed by the ld.AO and that upheld by ld. CIT(A) rejecting the Appellants Claim u/s.10 of the Act is incorrect and contrary to the provisions of section 154 of the Act. Accordingly, the appellants rectification application claiming exemption u/s. 10 of the Act be kindly allowed. Appellant be granted just and proper relief in this respect (Rs. 1,78,51,500/-) 2. On the facts and circumstances prevailing in the case and as per provisions & scheme of the Income-tax Act, 1961 ('The Act') it be held that order passed by the CIT(A) by wrongly assuming applicability of s.....

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....duction u/s. 11 of the Act. 3. Aggrieved by the order of the ITO, Exemption, assessee filed appeal before the ld.CIT(A), who upheld the order of ITO, Exemption. The ld.CIT(A) gave the reason for rejecting the assessee's appeal that issue involved is outside the ambit of s.154 and there is no mistake apparent from record. Aggrieved by the order of ld.CIT(A), assessee filed the present appeal before this Tribunal. Submissions of ld.AR:- 4 The ld.AR filed a paper book containing 61 pages. The ld.AR submitted that the assessee is running educational institution, which is substantially financed by the Government, whose grants are more than 90%. He further submitted that in the return of income, the assessee had claimed benefit of s.10(23C)(ii....