Sree Chithra Educational, Cultural And Film Society v. DIT (2019) 412 ITR 76 (Ker.)(HC)

S. 10(22) : Educational institution-Institution Should exist solely for educational purposes—Income from educational institution utilised to purchase immovable property in names of members of society—Not entitled to exemption.

Dismissing the appeal of the assessee the Court held that the assessee was a society formed with many objectives, one of which was imparting education. Hence, the assessee was not an institution established and existing solely for educational purposes. The Assessing Officer found that the funds of the society were diverted to purchase of assets, immovable property in the name of persons managing the society. The clear finding was that it could not be held that the institution was existing solely for educational purposes and not for profit. Hence the assessee was not entitled to exemption under section 10(22) of the Act.