TaxTMI 
TaxTMI 
2017 (6) TMI 1048
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.... Revenue challenging judgement of the Income Tax Appellate Tribunal dated 07.10.2016 raising following question for our consideration: "Whether the Appellate Tribunal is justified in directing the CIT(E), Ahmedabad to grant approval u/s. 10(23C)(vi) of the Act to the assessee and ignoring the finding of the CCIT, Baroda, as the applicant Trust does not fulfill the conditions laid down u/s. 10(23....
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.... been granted exemption under section 80G of the Act. 4. Despite such facts, the Commissioner, on the premise that clause (c) of the objects noted above stated to be for the education purpose, held that the Trust does not fulfill the condition of section 10 (23C)(vi) of the Act. He was of the opinion that the Trust was not existing solely for education purpose. He accordingly, by an order dated 2....
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....ction 10(23C), the ld. CCIT has not pointed out any specific aspect. He only harboured a belief that assessee might have some ancillary activities not associated with education. This is only a hypothetical observation. In all these decisions, it has been propounded that if the assessee has not taken other objections mentioned in the trust deed, the exclusively carried out activities of education, ....