DCIT, EXEMPTION, CIRCLE, JAIPUR, JAIPUR vs. RAJASTHAN STATE TEXT BOOK BOARD, JAIPUR

ITA 1424/JPR/2025Status: DisposedITAT Jaipur23 March 2026AY 2022-239 pages
AI SummaryAllowed

What did the Tribunal hold?

The ITAT held that the issue was squarely covered by its previous decisions in the assessee's own case, which had relied on a Rajasthan High Court ruling. Consequently, the tribunal allowed the claim of exemption under Section 10(23C)(iiiab) for the assessment years in question. The cross objections filed by the assessee regarding the validity of reopening were dismissed as academic.

What were the facts?

The Rajasthan State Text Book Board, engaged in printing and selling textbooks, claimed exemption under Section 10(23C)(iiiab) of the Income Tax Act. The Assessing Officer denied this exemption, stating the assessee was not an educational institution, didn't receive budgetary grants, and was engaged in commercial activity. The CIT(A) allowed the exemption, following previous ITAT orders.

What were the issues?

Eligibility of the assessee for exemption under Section 10(23C)(iiiab) by treating textbook sales as substantially financed by the Government, and the validity of assessment reopening.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 250

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Cases cited in this judgment(1)Show list

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Heard together (3 matters)

CO No.49/JPR/2025
CO No.50/JPR/2025
CO No.51/JPR/2025

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Page 1 Rajasthan State Text Book Board IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “B” BENCH, JAIPUR BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER & SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER ITA Nos.1332 to 1339 & 1423 to 1424/JPR/2025 (Assessment Years:2010-11 to 2018-19 & 2022-23)

Board 2-2A, Jhalana Doongari Jaipur 302015 स्थायीलेखासं./जीआइआरसं./PAN/GIR No:AAAAR6050Q Appellant Respondent CO No.49/JPR/2025 (Arising out of ITA No.1337/JPR/2025) (Assessment Year:2014-15)

Rajasthan State Text Book || Vs. DCIT Exemption, Board 2-2A, Jhalana Doongari Jaipur 302015 Circle, Jaipur स्थायीलेखासं./जीआइआरसं./PAN/GIR No:AAAAR6050Q Appellant Respondent CO No.50/JPR/2025 (Arising out of ITA No.1336/JPR/2025) (Assessment Year:2015-16)

Page 2 Rajasthan State Text Book Board Rajasthan State Text Book || Vs. DCIT Exemption, Board 2-2A, Jhalana Doongari Jaipur 302015 Circle, Jaipur स्थायीलेखासं./जीआइआरसं./PAN/GIR No:AAAAR6050Q Appellant Respondent CO No.51/JPR/2025 (Arising out of ITA No.1335/JPR/2025) (Assessment Year:2013-14)

Rajasthan St

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