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10(23C) are pari materia vide a later judgement of this Tribunal in the case of Shri Hari Ram Yadav Vs PCIT (ITA No. 215/JP/2018 dated 31.12.2018) wherein the issue has been decided in favour of the Department and therefore, the decision in case of Modern School Society stand distinguishable. 19. The ld CIT/DR further drawn our attention