The appeals are partly allowed
Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary
exempt in terms of sections 11 and 12 of the Act or other sections pertaining to exempt income, the same has to be brought to tax irrespective of the status of the person. The taxing ITA Nos.50, 51, 52, 53 & 54/ALLD/2023 & ITA Nos.5, 6, 7, 8 & 9/ALLD/2023 Page 74 of 79 statute has to be construed strictly even