iiiab) of the Act as it was
not wholly and substantially financed by the
Government. In the appeal, the appellate authority as
well ... Authorities
were correct in holding that the term "wholly
or substantially financed by the Government"
contemplated in 10(23C)(iiiab
exemption 10(23C)(iiiab) being an
educational institute wholly or substantially financed by
3
M/s.Rajiv Gandhi Proudyogiki Vishwavidyalaya,Bhopal.
Govt. could ... iiiab) being income of an Educational Institution
wholly or substantially financed by the State Government.
Therefore, the assessee university being governed by the
Rajiv Gandhi
assessee educational
institution can be considered to be on facts substantially
financed by the Government of Haryana and hence the case of
the assessee ... inserted prospectively and the vagueness attributable to the
words "substantially financed" could be said to have existed.
Th e fact that the inser
holding that the assessee is not wholly and substantially financed by the
Government and not eligible to claim exemption ... that the University or the educational institution should be wholly or
substantially financed by the government. This implies that the section only refers to
direct
without
appreciating the fact that the assessee is neither wholly
nor substantially financed by the Government in view of the
Explanation to subsection ... educational institution existing for the
purpose of education and substantially financed by the
Government. The institution is in existence for over 60 years
purposes of
profit, and which is wholly or substantially
financed by the Government: or
(iii(ac) any hospital or other institution for
the reception ... purposes of profit, and which is wholly or
substantially financed by the Government; or
(iii)(ad) any University or other
educational institution existing solely
College does fall within the meaning
of expression "wholly or substantially financed by the
Government" as employed in sub-clause (iiiab) of clause ... purposes of profit,
and which is wholly or substantially financed by the
Government;"
5.5. To ascertain whether an educational institution like the petitioner-
College
well as the
Tribunal was: whether the petitioner was wholly or substantially financed by
the government. In this case, the government is the Government ... purposes of profit, and which is wholly or substantially financed
by the Government.‖
[Explanation.--For the purposes of sub-clauses (iiiab) and (iiiac), any
university
appropriate
Government, and includes any--
(i) body owned, controlled or substantially financed;
(ii) non-Government organization substantially financed, directly
or indirectly by funds provided ... petitioner can
be said to be a body „controlled or substantially financed by the government‟.
There is no material on record to show that
purposes of profit, and which is wholly or
substantially financed by the Government;"
3.4 If the language used in sub-section is analysed ... profit and at the same time,
which is wholly or substantially financed by the Government. We
have asked the assessee to produce its purposes
