Assessee-society was running two educational institutions. It had earned gross receipts of less than Rs. 1 crore from each school. Assessee claimed that since it was existing solely for educational purpose, income earned by it would be exempted from tax as per provisions of section 10(23C)(iiiad) read with rule 2BC of Income-tax Rules, 1962. Assessing Officer denied exemption on ground that assessee had received total receipts of Rs. 1.25 crore which was more than Rs. 1 crore. CIT(A) up held the order of the AO. On appeal the Tribunal held that since annual income was less than Rs. 1 crore from each school and existing solely for educational purposes, income of assessee is exempt from tax.(AY. 2018-19)
ICF Silver Jubilee Nursery & Primary School. v. DCIT (2025) 212 ITD 72 (Chennai) (Trib.)
S. 10 (23C): Educational institution-Two educational institutions-Each educational institution had earned gross receipts of less than Rs. 1 crore from each school-Income is exempted from tax as per provisions of section 10(23C)(iiiad) of the Act.[S. 10(23C)(iiiad)]