https://www.taxtmi.com/caselaws?id=797542 Educational wings operated by the same society cannot be treated as separate institutions for the monetary threshold under section 10(23C)(iiiad) merely because they have different names or provide different levels of education. Where operations share a common campus, management, ownership and infrastructure, and lack separate books of account and independent administration, they constitute one composite educational establishment. Their annual receipts must therefore be aggregated. Fragmenting receipts without proof of independent existence would undermine the threshold intended for genuinely small educational institutions, resulting in denial of the exemption where aggregated receipts exceed the prescribed limit. en-us Mon, 03 Aug 2026 00:00:00 +0530 Mon, 24 Aug 2026 08:33:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797542 Educational wings operated by the same society cannot be treated as separate institutions for the monetary threshold under section 10(23C)(iiiad) merely because they have different names or provide different levels of education. Where operations share a common campus, management, ownership and infrastructure, and lack separate books of account and independent administration, they constitute one composite educational establishment. Their annual receipts must therefore be aggregated. Fragmenting receipts without proof of independent existence would undermine the threshold intended for genuinely small educational institutions, resulting in denial of the exemption where aggregated receipts exceed the prescribed limit. Case-Laws Income Tax Mon, 03 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797542