Case Law Analysis
|Income Tax Appellate Tribunal
Section 12A(1)(ac)(ii) | No University Affiliation Required for Educational Exemption if Activities Are Purely Non-Profit & Educational : ITAT Delhi
The ITAT Delhi has ruled that an educational institution qualifies for tax exemption under Section 12A(1)(ac)(ii) even without formal affiliation to a university or board, provided its objects and activities are exclusively educational and non-profit. This clarifies a critical ambiguity for small schools, nurseries, and alternative education trusts seeking tax status without institutional ties, reinforcing that substance overrides formality under the Income-tax Act.