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Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether an educational institution is disentitled to approval under section 10(23C)(vi) merely because one of its objects, properly construed, is ancillary or incidental to the dominant educational purpose.
Analysis: Approval under section 10(23C)(vi) is available where the institution exists solely for educational purposes. However, where the dominant purpose is education, a further object that is merely ancillary or incidental does not defeat eligibility. The relevant test is whether the impugned object is a main non-educational purpose or only an adjunct to the educational purpose. On a fair reading of the object clause, the impugned object concerning admission of child labour-affected children was treated as incidental to the educational objects of the society and not as a separate disqualifying purpose.
Conclusion: The objection to approval was held unsustainable, and the matter was sent back for grant of exemption if the remaining conditions were satisfied.
Ratio Decidendi: An institution does not lose eligibility under section 10(23C)(vi) if a questioned object is merely ancillary or incidental to its primary educational purpose; disqualification arises only when the non-educational object is itself a main or independent object.
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