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Additional Commissioner Of Income-Tax ... vs Surat Art Silk Cloth Manufacturers ... on 19 November, 1979

"The final conclusion that if a surplus is made by an educational society and ploughed back to construct its own premises would fall out of Section 10(23C) is to ignore the language of the section and to ignore the tests laid down in Surat Art Silk Cloth case [CIT v. Surat Art Silk Cloth Manufacturers' Assn.[1980] 2 SCC 31], Aditanar case [Aditanar Educational Institution v. CIT [(1997) 3 SCC 346] and American Hotel & Lodging case [American Hotel & Lodging Assn. Educational Institute ITA No.425/Bang/2017 Page 12 of 16 v. CBDT [(2008) 10 SCC 509]. It is clear that when a surplus is ploughed back for educational purposes, the educational institution exists solely for educational purposes and not for purposes of profit."
Supreme Court of India Cites 45 - Cited by 2322 - P N Bhagwati - Full Document

M/S Queen'S Educational Society vs Commr.Of Income Tax on 16 March, 2015

6. The relevant principles of law which will govern the first issue i.e. whether an educational institution or a university, as may be, exists only for educational purpose and not for profit are no longer res integra, having been dealt with by ITA No.425/Bang/2017 Page 11 of 16 a long line of decisions of this Court which have been elaborately noticed and extracted in a recent pronouncement i.e. Queen's Educational Society v. CIT [2015] 372 ITR 699/231 Taxman 286/55 taxmann.com 255 (SC).
Supreme Court of India Cites 37 - Cited by 180 - R F Nariman - Full Document

Aditanar Educational Institution vs Additional Commissioner Ofincome-Tax on 5 February, 1997

"The final conclusion that if a surplus is made by an educational society and ploughed back to construct its own premises would fall out of Section 10(23C) is to ignore the language of the section and to ignore the tests laid down in Surat Art Silk Cloth case [CIT v. Surat Art Silk Cloth Manufacturers' Assn.[1980] 2 SCC 31], Aditanar case [Aditanar Educational Institution v. CIT [(1997) 3 SCC 346] and American Hotel & Lodging case [American Hotel & Lodging Assn. Educational Institute ITA No.425/Bang/2017 Page 12 of 16 v. CBDT [(2008) 10 SCC 509]. It is clear that when a surplus is ploughed back for educational purposes, the educational institution exists solely for educational purposes and not for purposes of profit."
Supreme Court of India Cites 12 - Cited by 101 - Full Document

American Hotel And Lodging Association ... vs The Central Board Of Direct Taxes, ... on 24 November, 2006

"The final conclusion that if a surplus is made by an educational society and ploughed back to construct its own premises would fall out of Section 10(23C) is to ignore the language of the section and to ignore the tests laid down in Surat Art Silk Cloth case [CIT v. Surat Art Silk Cloth Manufacturers' Assn.[1980] 2 SCC 31], Aditanar case [Aditanar Educational Institution v. CIT [(1997) 3 SCC 346] and American Hotel & Lodging case [American Hotel & Lodging Assn. Educational Institute ITA No.425/Bang/2017 Page 12 of 16 v. CBDT [(2008) 10 SCC 509]. It is clear that when a surplus is ploughed back for educational purposes, the educational institution exists solely for educational purposes and not for purposes of profit."
Delhi High Court Cites 16 - Cited by 148 - M B Lokur - Full Document
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