No exemption U/s. 10(23C)(vi) if Educational institution not exists solely for education

Sutlej Educational Charitable Trust Vs CIT (E) (ITAT Amritsar) The only issue, thus, that survives is that the funds (or income) of the educational institution are (or, is) not to be utilized by the assessee-trust, owning and managing it, for any other (non-educational) object/purpose, which, as afore-noted, there are several (also refer para 2 of the impugned order/cl. 3 of the trust deed). That is as where the funds of an educational institution are used by the person in receipt thereof for any other purpose, even if charitable, it cannot be said that the said educational institution exists ...