Exemption under Section 10(23C)(vi) requires complete financial material and proper review of the governing university statute.

An exemption application under Section 10(23C)(vi) must be decided on complete relevant material and in light of the governing statutory framework. The rejection here was unsustainable because the authority had not considered the final income and expenditure figures and had not properly examined the effect of the Gujarat Private Universities Act, 2009 on the institution's status and control. The order was quashed and the matter remanded for fresh consideration after hearing the petitioner and evaluating the relevant provisions and record.

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Issues: Whether the order rejecting exemption under Section 10(23C)(vi) could be sustained when it was passed without considering complete and relevant financial material and without properly examining the statutory framework governing the private university.

Analysis: The petitioner sought exemption as an educational institution under Section 10(23C)(vi) of the Income-tax Act, 1961. The refusal was challenged on the ground that the authority had proceeded on incomplete material, particularly without the final income and expenditure figures up to 31.03.2014, and had not adequately considered the powers and control of the State Government under the Gujarat Private Universities Act, 2009. The record showed that the application was dealt with before the relevant financial material was available, and the authority was required to examine the matter in the light of the governing university statute and the submissions made by the petitioner.

Conclusion: The rejection order could not be sustained and was quashed. The matter was remanded to the Chief Commissioner for fresh consideration of the exemption application after giving the petitioner an opportunity of hearing and after considering the relevant statutory provisions and materials.

Final Conclusion: The petitioner obtained a remand for reconsideration of its exemption claim on a proper factual and legal basis.

Ratio Decidendi: An exemption request under Section 10(23C)(vi) must be decided on complete relevant material and by considering the governing statutory regime applicable to the institution.

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