No denial of Sec. 10(23C) relief on mere generation of incidental surplus by educational institution

IT : Increase in the fees for generating surplus would not by itself exclude the petitioner from the ambit of section 10(23C)(vi) of the Act. Generation of profit or surplus by an organization cannot be construed to mean that the purpose of the organization is generation of profit/surplus, as long as the surpluses generated are accumulated /utilized only for educational purposes. The same would not disable the institution from claiming exemption under section 10(23C)(vi) of the Act.