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    <title>2006 (7) TMI 523 - ITAT MUMBAI</title>
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    <description>Exemption for educational institutions under section 10(22) must be tested school-wise, and incidental surplus does not by itself defeat the exemption if the dominant object remains education. On the facts noted, unaccounted collections, unrecorded payments and trustee benefit disentitled the assessee for the earlier years, while no adverse material was found for the later year. Exemption under section 11 likewise depended on compliance with trust conditions and absence of personal benefit under section 13(1)(c); misuse of trust funds for trustees led to denial for the earlier years, but the later year was not affected. An estimated profit addition on sale of uniforms and allied materials was unsustainable without supporting material, while the other disputed additions were upheld and donations, absent proof of corpus character, were treated as income.</description>
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    <pubDate>Fri, 28 Jul 2006 00:00:00 +0530</pubDate>
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      <title>2006 (7) TMI 523 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=120084</link>
      <description>Exemption for educational institutions under section 10(22) must be tested school-wise, and incidental surplus does not by itself defeat the exemption if the dominant object remains education. On the facts noted, unaccounted collections, unrecorded payments and trustee benefit disentitled the assessee for the earlier years, while no adverse material was found for the later year. Exemption under section 11 likewise depended on compliance with trust conditions and absence of personal benefit under section 13(1)(c); misuse of trust funds for trustees led to denial for the earlier years, but the later year was not affected. An estimated profit addition on sale of uniforms and allied materials was unsustainable without supporting material, while the other disputed additions were upheld and donations, absent proof of corpus character, were treated as income.</description>
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      <pubDate>Fri, 28 Jul 2006 00:00:00 +0530</pubDate>
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