G.H.R. Education Foundation, Nagpur vs. CIT Exemption, Pune
ITA 615/NAG/2024[--]Status: DisposedITAT Nagpur10 Feb 2025
Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member
For Appellant: Shri Mukesh AgrawalFor Respondent: Shri Sandipkumar Salunke
Section 10Section 366Section 8Section 80G
…, the proviso cannot prevail. Though in absolute terms of a later Act. Its placement has been considered, and purpose has been considered in the following decisions. It was observed in State of Rajasthan v. Leela Jain [State of Rajasthan v. Leela Jain, (1965) 1 SCR 276: AIR 1965 SC 1296]: (AIR p. 1300, para 14) "14.... So far as a general principle of construction of a proviso is concerned, it has been broadly stated that the function of a proviso is to limit the main part of the section and carve out something which but for the proviso would have been within the operative part. Mangalore Chemicals and Fertiliser…