Exemption Denied u/s 10(23C)(vi) Despite Surplus Funding Education; Decision Misaligned with Tax Board Guidelines.

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....Approval for exemption u/s 10 (23C) (vi) denied - existing solely for the educational activities or not - If the surplus is utilized for educational activities then it cannot be said that it is an institution existing for the profit. In the present case, the surplus was utilized only for educational purposes. No evidences lead before us to show that any of the income earned by the assessee institution has been spent for non-educational purposes. This is in consonance with paragraph number 3 of the circular issued by the central board of direct taxes. Thus on this basis, rejection of the exemption claim of the assessee is not justified. - AT....