Facts of the Case
The assessee, Hidayatullah National Law University, a
State-established institution engaged in imparting legal education, claimed
exemption under Section 10(23C)(iiiab) for Assessment Years 2016-17 and
2017-18.
During assessment proceedings, the Assessing Officer examined
the University's receipts and Government grants and observed that:
- Government
grants constituted 47.85% of total receipts for AY 2016-17.
- Government
grants constituted 9.77% of total receipts for AY 2017-18.
The Assessing Officer held that Rule 2BBB mandates that
Government grants must exceed 50% of total receipts during the relevant
previous year for an institution to be regarded as substantially financed by
the Government. Since the prescribed threshold was not met, exemption under
Section 10(23C)(iiiab) was denied.
The assessee contended that cumulative Government support,
including grants, infrastructure, land allotment and financial assistance
received since inception, should be considered while determining substantial
financing.
The CIT(A)/NFAC upheld the Assessing Officer's action.
Aggrieved, the assessee preferred an appeal before the Income Tax Appellate
Tribunal.
Issues Involved
- Whether
the expression “substantially financed by the Government” under Section
10(23C)(iiiab) is governed by Rule 2BBB.
- Whether
cumulative Government funding received since inception can be considered
for determining substantial Government financing.
- Whether
land allotment, infrastructure support and capital assistance can be
included while computing Government financing under Rule 2BBB.
- Whether
an educational institution can claim exemption under Section
10(23C)(iiiab) when Government grants during the relevant previous year
are less than 50% of total receipts.
Petitioner’s Arguments
The assessee-University submitted that:
1. Government-Created Educational Institution
The University was established under a State enactment and
operated under Government supervision and control.
2. Holistic Approach to Government Financing
The test of substantial financing should not be confined to
grants received during a single previous year.
3. Consideration of Capital and Infrastructure Support
Government contributions through:
- Initial
corpus funding
- Capital
grants
- Land
allotment
- Infrastructure
support
- Other
financial assistance
should also be considered.
Respondent’s Arguments
The Revenue contended that:
1. Mandatory Statutory Requirement
Section 10(23C)(iiiab) applies only where an institution is
wholly or substantially financed by the Government.
2. Rule 2BBB Provides the Definitive Test
Rule 2BBB clearly prescribes that Government grants must
exceed 50% of total receipts during the relevant previous year.
3. Threshold Not Satisfied
Government grants constituted:
- 47.85%
for AY 2016-17
- 9.77%
for AY 2017-18
Therefore, the statutory benchmark was not met.
4. Relevant Previous Year is Determinative
Only Government grants received during the relevant previous
year can be considered.
5. Capital Support Irrelevant
Land allotment, infrastructure facilities and historical
assistance cannot be considered under Rule 2BBB.
6. Strict Interpretation of Exemption Provisions
Exemption provisions must be strictly construed and the
statutory conditions must be satisfied exactly.
7. Distinguishable Judicial Precedents
The decisions relied upon by the assessee were distinguishable
and could not override the specific framework introduced through Rule 2BBB.
Court Findings / ITAT Observations
1. Rule 2BBB is the Governing Provision
The Tribunal held that the expression “substantially financed
by the Government” must be interpreted strictly in accordance with Rule 2BBB.
2. Year-wise Examination is Mandatory
The Rule requires examination of:
- Government
grants received during the relevant previous year; and
- Total
receipts of the same previous year.
3. Historical Funding Cannot Be Considered
The Tribunal rejected the argument that cumulative Government
funding since inception should be considered.
4. Land and Capital Assistance Excluded
Government support through land allotment, infrastructure
creation, corpus contributions and capital grants cannot substitute the
statutory requirement under Rule 2BBB.
5. Failure to Meet the 50% Benchmark
Government grants were below the prescribed threshold in both
years.
6. Strict Construction of Exemption Provisions
Once Rule 2BBB prescribes a numerical benchmark, Courts cannot
substitute alternative tests based on equitable considerations.
7. Karnataka High Court Decision Distinguished
The decision in CIT v. Indian Institute of Management was
distinguished on facts and legal context.
Court Order
The ITAT held that:
- Government
grants constituted only 47.85% of total receipts for AY 2016-17.
- Government
grants constituted only 9.77% of total receipts for AY 2017-18.
- The
statutory threshold prescribed under Rule 2BBB was not satisfied.
- The
University could not be regarded as substantially financed by the
Government.
Accordingly:
- Exemption
under Section 10(23C)(iiiab) was denied.
- Orders
of the Assessing Officer and CIT(A) were upheld.
- Appeals
of the assessee were dismissed.
Important Clarification
The Tribunal categorically clarified that:
·
Only Government grants received during the
relevant previous year are relevant.
·
Cumulative Government funding since inception is
irrelevant.
·
Historical grants cannot be aggregated with
current-year grants.
·
Land allotment, infrastructure support and capital
assistance cannot be considered for satisfying Rule 2BBB.
·
Government grants must exceed 50% of total
receipts in the relevant previous year.
·
Even a marginal shortfall below 50% results in
denial of exemption.
Sections Involved
- Section
10(23C)(iiiab), Income-tax Act, 1961
- Rule
2BBB of the Income-tax Rules, 1962
- Explanation to Section 10(23C)(iiiab)
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