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Further, looking at the financials of the assessee and the surplus generated, learned Commissioner (Exemp.) observed, it does not satisfy the condition of "not existing for the purpose of earning profit". Thus, broadly on the aforesaid premises, he rejected assessee's application seeking exemption under section 10(23C)(vi) of the Act. Being aggrieved with the aforesaid decision of learned Commissioner (Exemp.),

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Section 10(23C) of the Income Tax Act, 1961 — Exemption — Matter remanded back for disposal afresh as AO rejected assessee's claim for Exemption under section 10(23C) (vi) without giving it any sufficient opportunity to furnish all documentary evidences and material to demonstrate that it had imparted training/education in respect of courses offered — Indian Institute of Banking and Finance vs. Commissioner of income tax [2019] 178 ITD 833 (Mumbai-trib)

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