University Wins Appeal: Tax Exemption Upheld; Tribunal Quashes CIT(E)'s Revision on Government Financing Rule Interpretation.

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....The assessee, a university, claimed exemption u/s 10(23C)(iiiab) for the relevant assessment year, which was accepted by the Assessing Officer (AO) after considering the applicable laws and facts. The AO included interest income on government grants in calculating the government financing, which exceeded 50% of the total income, meeting the substantial financing threshold. The Commissioner of Income Tax (Appeals) [CIT(E)] invoked Section 263, revising the AO's order as prejudicial to revenue, by excluding interest income and applying Rule 2BBB retrospectively. The Appellate Tribunal held that the AO correctly allowed the exemption based on the prevailing legal framework, judicial precedents, and facts. The exclusion of interest income and r.........