https://www.taxtmi.com/caselaws?id=766695 The ITAT Ahmedabad reversed the CIT(A)'s decision allowing exemption under section 10(23C)(vi) to an educational trust. While the CIT(A) held that hostel facilities were integral to educational purposes and surplus funds were reinvested, the ITAT found error in this reasoning. Following the SC decision in Ahmedabad Urban Development Authority, the ITAT distinguished between charitable hostel provision integrated with education versus commercial hostel operations. The tribunal held that where fees substantially exceed costs, the activity constitutes trade/commerce/business, disqualifying the trust from exemption unless within prescribed limits. The revenue's appeal was allowed, denying the trust's tax exemption claim. en-us Tue, 11 Feb 2025 00:00:00 +0530 Mon, 03 Mar 2025 08:22:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766695 The ITAT Ahmedabad reversed the CIT(A)'s decision allowing exemption under section 10(23C)(vi) to an educational trust. While the CIT(A) held that hostel facilities were integral to educational purposes and surplus funds were reinvested, the ITAT found error in this reasoning. Following the SC decision in Ahmedabad Urban Development Authority, the ITAT distinguished between charitable hostel provision integrated with education versus commercial hostel operations. The tribunal held that where fees substantially exceed costs, the activity constitutes trade/commerce/business, disqualifying the trust from exemption unless within prescribed limits. The revenue's appeal was allowed, denying the trust's tax exemption claim. Case-Laws Income Tax Tue, 11 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766695