Where SAIESF was established in the United States wholly and exclusively for charitable and educational purposes and was founded for the sole purpose of assisting and supporting assessee trustees, and where all expenditure incurred by SAIESF were for the educational purpose of assessee trust, exemption claimed by assessee trust under section 10(23C)(vi) could not have been refused; revenue could not have enquired about receipts and expenses made by SAIESF outside the country merely because was transferring its surplus or even a portion thereof to assessee trust in India – Laura Entwistle v. Union of India – [2023]
