10(23C)(vi) Exemption Wrongly Denied; Surplus Development Fund Not Proof of Profit Motive

Vaish Model Primary School Education Society Vs AO (Exemptions) (ITAT Delhi)

Assessee, a long-established educational society in Haryana, applied for approval u/s 10(23C)(vi) for AY 2009-10 onwards. Its application, filed in 2009, faced repeated rejections by CCIT/CIT(E) in 2010, 2012 and 2024, mainly on two grounds:

(i) surplus transferred to the School Development Fund, and

(ii) society allegedly “generating substantial surplus year after year.”

Each rejection was challenged; Punjab & Haryana Hig

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