Allowing the petition the Court held that ;the assessee was a society registered under the Societies Registration Act, 1860 . Its main purpose, aims and objects, as stated in its memorandum of association was to impart education along with ancillary objects. Accordingly the denial of exemption was not justified only on the ground that institution has earned surplus .
J. B. Memorial Manas Academy Management Society. v. CIT (2018) 408 ITR 255/ 259 Taxman 537 (Uttarakhand) (HC)
S. 10 (23C): Educational institution-Exemption cannot be denied only on the ground that institution has earned surplus when the institution is solely for educational purposes .