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2015 (11) TMI 1816 - ITAT CHENNAIDenying exemption u/s 10(23C)(vi) - assessee trust is solely engaged for educational purposes and thus there is no justification in denying exemption u/s 10(23C)(vi) though the trust deed was amended subsequently by the assessee - HELD THAT:- As perused the order of the Chief Commissioner. On a perusal of the object clauses of the trust deed, we find that the assessee is established not only for managing all types of educational institutions but also to promote finance, hospitals, research centers in medical science. On a perusal of the profit and loss account and income & expenditure account of the assessee, we find that the assessee incurred certain expenditure towards awareness on agriculture, awareness on scientific research programme and blood donor camp expenses, medical treatment expenses, free eye camp activity which goes to show that assessee’s activities are not confined only to the education during the year ended 31.03.2014. The Chief Commissioner also observed that assessee trust amended its deed only on 29.07.2015 which is beyond the year ended 31.03.2014, therefore not relevant for the assessment year 2014-15 and he denied exemption holding that assessee trust is existing not only for education but also for other activities. We do not find any infirmity in coming to the conclusion by the Chief Commissioner in rejecting the application for exemption under section 10(23C)(vi) - Decided against assessee.
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