Supreme Court line on section 10(23C)(vi) applies: trust with non-educational objects not entitled to exemption

5-Second Takeaway

A trust seeking exemption under section 10(23C)(vi) must have all its objects aimed at imparting or facilitating education; if it has other objects, exemption is not available. The Court held that this trust could not be said to exist solely for educational purposes and was therefore rightly denied approval.

The case concerned a trust’s claim for approval under section 10(23C)(vi). The prescribed authority refused the claim after examining the trust deed and finding that the objects were not confined to education alone.

The trust argued that it was essentially educational. The Court rejected that contention, noting that the exemption is available only where the trust, university or institution is found to exist solely for advancing education.

On the terms of the deed, the trust had several objects beyond education. The Court therefore held that it could not conclusively be treated as a body formed only for educational purposes.

Relying on the Supreme Court’s decisions in New Noble Educational Society and Baba Banda Singh Bahadur Education Trust, the Court upheld the refusal of exemption. The result was that approval under section 10(23C)(vi) was denied.