University's Tax Status: Educational Services Exempt, Non-Educational Income Taxable Unless Notified. Affiliation Fees Not Taxable.

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....Writ petition maintainable. Respondent-University qualifies as 'educational institution'. Income from specified educational services not taxable due to Negative List. Income from non-educational activities like building rent taxable unless exempt under notifications. Affiliation fees, penalties, fines not 'activity for consideration', hence not taxable. Exemption notifications applicable, not contrary to parent statute. Difference between Negative List and exemption notifications explained. University provides auxiliary educational services, eligible for exemption under relevant notifications.....