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of The HC dismissed a petition challenging denial of exemption under section 10(23C)(vi) of the Income Tax Act. The petitioner-trust argued that income received solely for educational purposes should be exempt. However, the Court upheld the Chief Commissioner of Income Tax's determination, noting that the exemption was claimed by the trust itself rather than by the specific educational institution (GHG Academy) it operated. Since it could not be conclusively established that the trust existed solely for educational purposes and not for profit, the Court found that exemption was correctly denied under the statutory requirements.
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