JUDGMENT judgment of court was delivered by N. Kumar J.-The Revenue has preferred these appeals against order passed by Tribunal dismissing appeal filed by Revenue and allowing appeal filed by assessee and granting relief to assessee. impugned order relates to assessment years 2003-04 and 2005-06, where common order is passed. As question involved is same, appeals are taken up for consideration together and disposed of as other two appeals also arise out of same order. assessee is running number of educational institutions. assessee filed its return of income. Assessing Officer under section 143(3) of Income-tax Act, 1961 (hereinafter referred to as "the Act"), has held that assessee is not entitled to benefit claimed under section 11 of Act. He did not go into question of exclusion benefit claimed by assessee under section 10(23C)(iiiab) of Act. Aggrieved by said order assessee preferred appeal to Commissioner of Income-tax (Appeals). Appellate Commissioner set aside order of assessing authority refusing grant under section 11 of Act and granted relief to assessee but he declined to grant relief under section 10(23C)(iiiab) of Act. Aggrieved by said order, both assessee as well as Revenue preferred two appeals each. Tribunal by its impugned order has set aside order passed by Appellate Commissioner holding that assessee is not entitled to benefit under section 10(23C)(iiiab) of Act and allowed appeals filed by assessee. It dismissed appeals of Revenue on ground that, once benefit is granted under section 10(23C)(iiiab) of Act, assessee is also entitled to benefit under section 11 and, therefore, Revenue's appeals were dismissed. Aggrieved by impugned order, these appeals are filed. In so far as claim of assessee under section 10(23C)(iiiab) of Act is concerned, material on record discloses that Government has financed institutions and their share is roughly about 25 per cent. It is not in dispute that assessee is carrying on its activities of imparting education. It is not existing for sake of profit-making. When 25 per cent. of finance to assessee-institutions flows from Government it constitutes substantial finance and, therefore, it has satisfied all legal requirements provided under section 10(23C)(iiiab) of Act. In fact, this court had occasion to consider said question in case of CIT v. Indian Institute of Management reported in [2015] 370 ITR 81 (Karn) and finance to extent of more than 10 per cent. of total finance would constitute substantial finance and, therefore, finding recorded by Tribunal that assessee is entitled to benefit exempted under section 10(23C)(iiiab) of Act cannot be found fault with. In light of aforesaid findings, in our view, it is unnecessary to go into question whether assessing authorities were justified in reopening assessment and there was sufficient reasons and whether assessee is entitled to benefit under section 11 of Act also. Accordingly, we pass following: Order Appeals are dismissed. Parties to bear their own costs. question, whether once benefit under section 10(23C)(iiiab) of Act is granted, grant of exemption under section 11 of Act is attracted or not is not gone into. It shall be decided as and when occasion arises before appropriate court. Therefore, finding of Tribunal to that extent is kept open to be agitated in appropriate forum and it will not act as precedent in future assessment. *** Director of Income-tax (Exemptions) v. Dhamapakasha Rajakarya Prasakta B. M. Sreenivasaiah Educational Trust