The CIT refused to grant exemption on the ground that the school was not registered as a separate entity with the IT Department did not have its own PAN. On appeal, the ITAT following the decision of CIT vs. Children Education Society (2013) 358 ITR 373 (Kar) held that, when the assessee was running a school for educational purposes and not for earning profit, then it was entitled to the exemption under s. 10(23C)(vi) of the Act. (AY. 2016-17)