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The Tax Publishers2020 TaxPub(DT) 1010 (P&H-HC) INCOME TAX ACT, 1961
Section 10(23C)
Where assets of assessee, i.e., its land and building etc. had been created out of donations received for setting up of school of society and object for upliftment of general public especially women was only with regard to its sole object of educational purpose only, assessee was entitled for exemption/approval under section 10(23C)(vi).
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Charitable trusts - Exemption under section 10(23C) - Object of 'social work for women uplifting' whether covered under clause prescribing education purposes -
Revenue challenged order of Tribunal holding assessee entitled for exemption/approval under section 10(23C)(vi) of the Income Tax Act, 1961. Issue raised was that object 'to work for social, moral, intellectual upliftment of general public especially women' brings the object of the assessee out of the phrase 'solely for educational purpose'. Held: Tribunal noted that assets of assessee, i.e., its land and building etc. had been created out of donations received for setting up of school of society. Contention raised was not well founded. From objects of assessee, it was forthcoming that it was promoting quality education in rural areas and managing affairs of Rural Public School. Object for upliftment of general public especially women is only with regard to its sole object of educational purpose only, as the intellectual upliftment of general public especially women can only envisage education and nothing else.
REFERRED : Visvesvaraya Technological University v. Asstt. CIT 2016 TaxPub(DT) 3834 (SC)
FAVOUR : In assessee's favour
A.Y. :
IN THE PUNJAB & HARYANA HIGH COURT
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