https://www.taxtmi.com/caselaws?id=244063 Section 10(23C)(iiiab) exemption requires an educational institution to be a university or educational institution, exist solely for education, not operate for profit, and be wholly or substantially financed by the Government. On the facts, Government grants formed only a minor part of the University's receipts, so the financing test was not met. The Court also applied the predominant object test and held that consistently large surpluses invested to earn interest showed systematic profit-making rather than a reasonable surplus. It further held that a statutory university is a distinct body corporate and not the State for article 289(1), so it cannot claim constitutional immunity from taxation. en-us Fri, 20 Dec 2013 00:00:00 +0530 Sat, 27 Jun 2026 11:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=244063 Section 10(23C)(iiiab) exemption requires an educational institution to be a university or educational institution, exist solely for education, not operate for profit, and be wholly or substantially financed by the Government. On the facts, Government grants formed only a minor part of the University's receipts, so the financing test was not met. The Court also applied the predominant object test and held that consistently large surpluses invested to earn interest showed systematic profit-making rather than a reasonable surplus. It further held that a statutory university is a distinct body corporate and not the State for article 289(1), so it cannot claim constitutional immunity from taxation. Case-Laws Income Tax Fri, 20 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=244063