Mere Presence of other objects does not mean that Institution was not existing Solely for Educational Purpose

In the instant case, it is not disputed that the petitioner society is running an educational institution. Merely because there are other objects of the society does not mean that the educational institution is not existing solely for educational purpose. The emphasis of the word “solely” is in relation to the educational institution, which is running not for the purpose of making profit and is not in relation to the objects of the society. In American Hotel & Lodging Association, Educational Institute vs. CBDT 2008 (301) ITR 86 SC the authority is required to consider the nat...