Mahindra University Vs CIT (Exemption) (ITAT Hyderabad)
ITAT Hyderabad order on Approval/Registration under Section 80G Rejection – Charitable Activity Assessment
The assessee, Mahindra University, was established in May 2020 and since its inception, had been engaged in the core charitable activity of imparting education. The university was conducting thirty-five distinct educational programs covering undergraduate, postgraduate, and doctoral levels across five schools and four centers. It was on record that the university had an active enrolment of over 4,100 students supported by a faculty strength of 240 members. Over the years, the university had developed significant educational infrastructure, which included classrooms, hostels, auditoriums, and sports facilities.
The assessee university was further noted for its extensive academic collaborations with international institutions such as Centrale Ecole, France, Boston College, USA, and the University of Florida, USA, among others, thereby enhancing the educational exposure of its students. It also maintained active partnerships with reputed industry leaders like Nvidia Global, Tata Steel, Airbus Innovation Centre, DRDLK, and ISRO, aimed at integrating practical training with academic curricula, thereby improving the employability prospects of its students. The university campus itself spanned across 107 acres, equipped to provide holistic educational services.
In light of these facts, the assessee university was earlier granted approval under Section 10(23C)(vi) of the Income Tax Act by the Commissioner of Income Tax (Exemption), Hyderabad, vide order dated 10.02.2021, which recognized the university as an institution existing solely for the charitable purpose of imparting education.
