The case revolves around denying income tax exemption to an educational institution under Section 10(23C)(vi) of the Income Tax Act, 1961. The appellant had applied for exemption, claiming to be ... an educational institution existing solely for educational purposes and not for profit. The Central Board of Direct Taxes (CBDT) rejected the application on the grounds of non-compliance with newly inserted monitoring provisions, including the application of income. The institution challenged this rejection, arguing that the monitoring conditions should not affect its eligibility for exemption. The court examined the nature of the institution’s activities in India, its source and application of income, and the compliance requirements set by the CBDT, ultimately remitting the case for fresh consideration.