Held that all the objects of the assessee were not aimed at or related to imparting education or in relation to educational activities. The assessee provided copyright in the course material to certain publishing houses. These books would then be made available by the publishers across the country, in respect of which the assessee received royalty. Thus, it was evident that to provide copyright in the course material to the publishing houses and earn royalty from them, was to earn more profit and was not solely for the purpose of education. The assessee had modified its objectives and it could not be said to exist “solely” for the purpose of education. Denial of exemption under section 10(23C)(vi) of the Act is held to be justified.(AY.2016-17 to 2019-20)
Indian Institute of Banking and Finance v. CIT (2023)107 ITR 250 / 226 TTJ 43(Mum.)(Trib.)
S. 10 (23C): Educational institution-University or educational institution must exist solely for educational purposes and not for purpose of profit each year-Earning royalties from publications-Not existing solely for education but for profit-Not entitled to exemption. [S.10(23C)(vi) 10A,10B, 80IB]