Assessee had been funding Diocese of Jalandhar for past 3 years under head of education extension services and submitted that Diocese was engaged in running schools, promoting education in different places in Punjab. Commissioner denied grant of exemption on grounds that MoA of Diocese was not totally educational and funding sum of Rs. 1 crore to same was done with purpose of diverting assessee’s funds. High court affirmed the order of the Commissioner. (AY 2010-11)
St. Francis Convent School v. CBDT (2021) 130 taxmann.com 78 (P& H)(HC) Editorial : SLP of assessee was dismissed, St. Francis Convent School v. CBDT (2021) 282 Taxman 313 (SC)
S. 10(23C) : Educational institution-Diverting funds to another institution which was not existing solely for educational purposes-Not entitle for exemption. [S. 10 (23C(vi)]