Subscribe to the Bombay Chartered Accountant Journal Subscribe Now!

October 2026

Shri Sant Ram Memorial Education and Welfare Society v. Exemption Ward: Where a society runs multiple educational institutions from a common campus, receipts must be aggregated to determine exemption limits under section 10(23C)(iiiad).

By Jagdish T Punjabi, Chartered Accountant Devendra Jain & Aditya Bhatt, Advocates
Reading Time 3 mins

52. (2026) 189 taxmann.com 174 (Chd Trib)

Shri Sant Ram Memorial Education and Welfare Society v. Exemption Ward

A.Y.: 2018-19 Date of Order : 03.08.2026

Section: 10(23C)(iiiad)

Where the assessee-society ran multiple educational institutions from a common campus with common infrastructure, management and ownership and maintained only consolidated accounts, the receipts of all the institutions were to be aggregated for determining the exemption under section 10(23C)(iiiad), and since such receipts exceeded the prescribed limit, exemption was rightly denied.

FACTS

The assessee, a society registered under the Societies Registration Act and engaged in imparting education, filed its return for A.Y. 2018-19 declaring Nil income after claiming exemption of Rs. 23.22 lakhs under section 10(23C)(iiiad). During the relevant year, it ran Infinity Public School, SSR College of Education, Bachpan Play School and the Society itself.

Its case was selected for complete scrutiny primarily for claim of exemption under section 10(23C)(iiiad). The AO noted that the assessee had furnished only consolidated fin

You May Also Like