Summary
- The Mumbai ITAT has ruled that the Universal Education Missions Trust cannot split its school sections to stay under the ₹1 crore exemption limit under section 10(23C)(iiiad).
- The trust's combined receipts of ₹1,01,83,461 exceeded the threshold, leading to a denial of tax exemption for AY 2015–16.
- The Tribunal clarified that while separate accounts were maintained, the sections were not recognized as distinct institutions by educational authorities.
- This ruling emphasizes that losing an exemption does not equate to all collections being taxable income without considering allowable expenditures.
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