20th Proviso to section 10(23C) applies prospectively hence denial of exemption u/s. 10(23C)(vi) not justified

Harda Nagar Bal Vikas Samiti Harda Vs ITO (ITAT Indore) ITAT Indore held that there is no authority to deny exemption u/s. 10(23C)(vi) for non-filing return since 20th Proviso to section 10(23C) denying exemption for non-filing return u/s. 139(4C) came to statue from AY 2023-2024 only. Facts- The assessee-society is engaged in educational activity by running two educational institutions. Uptill AY 2016-17, the assessee’s income was fully exempted u/s 10(23C)(iiiad) as the annual receipts of educational institutions did not exceed the prescribed eligibility limit of Rs. 1 crore. However, for ...