Educational exemption under Section 10(23C) turns on genuine non-profit purpose; rejection set aside for fresh consideration.

Exemption under Section 10(23C)(vi) and (via) depended on whether the petitioner was an educational institution existing solely for educational purposes and not for profit. The rejection was found unsustainable because the competent authority had not considered complete material, including the question whether fee collection for conducting examinations resulted in profit. The order was therefore set aside and the matter remanded for fresh decision after both sides were given adequate opportunity to place all relevant documents and submissions, consistent with natural justice.

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Issues: Whether the petitioner was entitled to exemption under Section 10(23C)(vi) and (via) of the Income-tax Act, and whether the rejection order required interference and remand.

Analysis: The controversy turned on whether the petitioner satisfied the statutory requirements for approval as an educational institution existing solely for educational purposes and not for profit. The impugned rejection was found to have been made without complete material, particularly on the question whether the petitioner generated profit by collecting fees for conducting examinations. Since the relevant material had not been fully considered, the matter required reconsideration after giving both sides an opportunity to place all relevant documents and submissions before the competent authority.

Conclusion: The rejection order was unsustainable on the existing record and was set aside. The matter was remanded to the competent authority for fresh decision after affording adequate opportunity and following principles of natural justice.

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