Bench: Shri Chandra Poojari, Am & Shri George George K, Jm
36(i)(viia) and 43D is not applicable to your appellant is because even otherwise it is exempt u/s 80P and therefore the question of such a claim does not arise. In Income Tax there are other examples where similar activity is carried out, in one instance it is taxable in another it is not. For eg educational institutions