Exemption u/s 10(23C)(iv) could not be rejected if net surplus was less than 20% of Total Receipts under second proviso to sec 2(15)

Council for Leather Exports Vs DCIT (Exemption) (ITAT Chennai)

Conclusion: Exemption claimed under Section 10(23C)(iv) could not be rejected under second proviso to sec 2(15) if the net surplus was less than 20% of total receipts of the institution and assessee charged/collected only the actual expenditure from Govt as grant and members as participation charges therefore, in respect of these activities which was in furtherance of the objective of assessee, the profit could be considered for Numerator for the purpose compliance of second Proviso to sec 2(15).