Rajah Sir Annamalai Chettiar Foundation v. CCIT (2020) 426 ITR 539 / 271 Taxman 84 (Mad)( HC)

S.10(23C: Educational Institution —Trust deed disclosing profit motive — Not entitled to exemption [ S.10(23C)(vi)

Court held that the  fact that there was no clause for providing free education for children coming from different social and educational backgrounds and scholarship to underprivileged children showed that there was only profit motive and the institutions were to be run only out of fees collected by admitting children to their schools. The trust deed also seemed to indicate that the source of funds of the assessee-trust was only from the school fees to be collected during these financial years. Therefore, it could not be construed that the assessee-trust’s schools were not for the purpose of profit. The assessee was not entitled to exemption . (AY.2011-12 to 2013-14)