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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 ..... observation of the ld. CIT (A) that the assessee trust has given various interest free advances to the trustees 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. The prescribed limit for Section 10(23)(iiiad) is less than ₹ 1 crore. Hence, keeping in view that the annual receipt of the education institute is less than ₹ 1 crore, the education institute is solely involved in the educational activity and since the objects clause of the trust during the year under consideration is to carr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o educational institutions namely, Umalok Paramedical College and Umalok Nursing School. The trust has not been granted registration u/s 12AA. The assessee claimed exemption u/s 10(23C) on the grounds that it is engaged in running educational institutions and its total receipts are below ₹ 1 crore. During the course of assessment proceedings, the AO show caused as to why exemption claimed u/s 10(23C) shall not be disallowed since the trust has not been established solely for educational purposes. The assessee stated before the AO that the main object of the trust is to run solely for educational purposes and not for the purposes of profit and the annual aggregate receipts of the trust does not exceed ₹ 1 crore in each and eve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ated to the type of educational activities as it is part of expenditure related to organizing the camp which is part of imparting the education and field training. 8. The ld. DR relied on the orders of the authorities below. 9. Heard the arguments of both the parties and perused the material available on record. 10. We find that the assessee has duly registered with Indian Nursing Council (INC) and also with the State Nursing Council and granted permission to train and impart education of 40 students in the course of Auxiliary Nurse Midwife (ANM). Similarly, the assessee is also permitted to train 60 students for the course of General Nurse Midwife (GNM). These activities involve theoretical classes, practical training and fiel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Government69; or (iiiac) any hospital or other institution for the reception and treatment of persons suffering from illness or mental defectiveness or for the reception and treatment of persons during convalescence or of persons requiring medical attention or rehabilitation, existing solely for philanthropic purposes and not for purposes of profit, and which is wholly or substantially financed by the Government. [Explanation.-For the purposes of sub-clauses (iiiab) and (iiiac), any university or other educational institution, hospital or other institution referred therein, shall be considered as being substantially financed by the Government for any previous year, if the Government grant to such universit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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