Commissioner rejected application on ground that out of amount collected under head placement and training a sum had been spent towards providing food, lodging and transport to trainers, trainee and staff, etc. which could not be treated as expenditure incurred solely for education purposes. Court held that neither collection of amount towards placement and training nor its utilisation by assessee could be said to be in a manner that was not solely for educational purposes. CCIT was to be directed to grant exemption. (AY. 2009-10)
Orissa Trust of Technical Education and Training v. CCIT (2022) 287 Taxman 616 (Orissa)(HC)
S. 10(23C) : Educational institution-Education-Amount spent on towards food, lodging etc. of trainers/trainees-Educational activities [S. 10(23C)(vi)].