Dispute Over Income Tax Exemption for Educational Trusts: Revenue's Burden to Prove Non-Educational Activities u/s 10(23C)(vi.

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....Exemption u/s 10 (23C) (vi) - Burden lies upon the Revenue to bring on record the evidence to rebut the claim of the Appellant Trust and to establish that the activities carried out and the expenditure incurred by the Assessee Trust could not be related to the educational activities of the Appellant Trust by any stretch of imagination. - mere reference to the expenditure incurred and the Head of expenditure in question while rejecting the Application u/s 10(23C)(vi) of the Act is not enough to reject the Application under the provisions of the Act. - HC....