Denial of exemption u/s 10(23C)(vi) - CIT(E) observed the huge...

Denial of exemption u/s 10(23C)(vi) - CIT(E) observed the huge surplus which indicates that the activities are conducted with the motive of profit. - even if for any year the taxpayer is found to be existing solely for educational purposes and not for purposes of profit, the assessee still has to continuously satisfy this pivotal condition each and every year. - Since the assessee has been found to be not ‘existing’ solely for the purposes of education, denial of exemption u/s 10(23C)(vi) of the Act is upheld. - AT