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TMI Blog2020 (5) TMI 532X X X X Extracts X X X X X X X X Extracts X X X X ..... of the appellant trust for exemption under section 10(23C)(vi). 3. The several observations as made and inferences drawn are untenable, incorrect, unwarranted." 3. The additional grounds taken up by the assessee while letter dated 04.10.2017 are not pressed. 4. Facts relevant to the adjudication are that a search and seizure operation u/s 132 of the Income Tax Act, 1961 was conducted in M/s Umalok Charitable Trust and Dr. Atul Krishan group of cases. Incriminating documents relating to the assessee were found and seized. Accordingly, assessment proceedings u/s 153C read with section 153A were initiated by the AO. The assessee trust is running two educational institutions namely, Umalok Paramedical College and Umalok Nursing School. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ege and M/s Umalock Health Workers Training Centre. He has filed the details of cloth distribution, food distribution, medicine distribution and expenses of blood donation camp. It was argued that that assessee is into imparting education of nursing and training of paramedical staff. In order to impart the practical training and field exposure, various camps are conducted at rural areas in and around Meerut. During the camps, the medicines are distributed to the patients and provision of food and clothing is being made to the patients, volunteers and the participants. It was argued that it cannot be considered as an expenditure unrelated to the type of educational activities as it is part of expenditure related to organizing the camp which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and find that the assessee has given only an indemnity bond but not any loans to the trustees as per the record before us. Hence, it can be held that the assessee is found to be solely in the activity of education and no other activities have been undertaken by the assessee during the year. 11. The provisions of Section 10(23C) read as under: "Section 10(23C) (23C) any income received by any person on behalf of- [(iiiab) any university or other educational institution68 existing68 solely for educational purposes and not for purposes of profit, and which is wholly or substantially financed by the Government69; or (iiiac) any hospital or other institution for the reception and treatment of persons suffering from illness or mental def ..... X X X X Extracts X X X X X X X X Extracts X X X X
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