Shri Guru Hargobind Sahib Charitable Trust v. CBDT (2024) 340 CTR 219 / 240 DTR 441 (P&H)(HC)

S. 10 (23C): Educational institution-Approval by prescribed authority-Object is not found existed solely for advancing educational purposes-Denial of exemption is justified. [S. 10(23C)(vi), Art. 226]

Authority has rejected the contention and claim of the assessee-trust on the ground that as per the aims and objects of the trust, it is apparent that it has not only been formed for the purpose of advancing education, but is also for other purposes as mentioned in cl. 5(i), (j), (k), (l), (m), (n) and (o) of the trust deed.  On writ the Court held that exemption was claimed by the trust itself and not by an individual educational institute namely, GHG academy, therefore it cannot be conclusively said that the trust was found and existed solely for advancing education purposes, hence, it was rightly not granted exemption.  (AY. 2012-13)