Educational institution approval fails where non-educational objects are included and the dominant purpose is not exclusively education.

Approval under Section 10(23-C)(vi) is available only to an institution existing solely for educational purposes and not for profit. The governing test is whether the memorandum, activities, and use of income show exclusive devotion to education in substance and in fact; incidental welfare or allied activity does not satisfy the provision. Where the objects include non-educational purposes that are more than merely ancillary, the institution fails the statutory condition because funds may be applied to non-educational ends. On that basis, societies with mixed objects were held not entitled to approval, and refusal of approval was justified.

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Issues: Whether approval under Section 10(23-C)(vi) of the Income-tax Act, 1961 could be granted to societies whose objects included non-educational purposes, on the ground that they were not existing solely for educational purposes.

Analysis: Approval under Section 10(23-C)(vi) is available only to an educational institution existing solely for educational purposes and not for profit. The nature of the objects, activities, source and application of income must show that the institution is in substance and in fact devoted exclusively to education. The presence of non-educational objects in the memorandum or bye-laws is fatal where those objects are not merely ancillary or incidental to the dominant educational purpose, because the institution may at its discretion apply its funds to non-educational ends. The meaning of education for this provision contemplates formal instruction or schooling, and incidental welfare or allied activities do not suffice in the absence of actual educational activity.

Conclusion: The societies were not entitled to approval under Section 10(23-C)(vi) because their objects were not confined solely to education; the refusal of approval was justified and is upheld.

Ratio Decidendi: An institution qualifies for approval under Section 10(23-C)(vi) only if its objects and activities show that it exists exclusively for education and not for profit, and non-educational objects that are not merely ancillary defeat the claim.

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