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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 Manufacturer's Association [1980] 2 SCC 31) Aditanar case (Aditanar Educational Institution v. CIT [1997] 3 SCC 346) and American Hotel & Lodging Association, Educational Institute v. CBDT [2008] 10 SCC 509). It is clear that when a surplus is ploughed back for educational 43 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

The Pr. Commissioner Of Income Tax -1 vs Jodhpur Development Authority on 13 August, 2021

34. Thereafter taken into consideration the decision of the Hon'ble Supreme Court in the case of ACIT Vs Surat City Gymkhana (2008) 14 SCC 169, CIT-1, Jodhpur Vs Jodhpur Development Authority (2016) 287 CRT 473 (Raj),Tamil Nadu Cricket Association Vs DIT (2013) 86 CCH 212, DIT(E) Vs The Chembur Gymkhana (2012) 345 ITR 86 and DIT(E) Vs Khan Gymkhana (2016) 385 ITR 162 (Bom) has decided the matter in favour of the assessee and against the department and the findings and the directions of the Hon'ble Rajasthan High Court are contained at para 8 to 12 of its order which read as under:
Rajasthan High Court - Jodhpur Cites 0 - Cited by 7 - V Bishnoi - Full Document
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