Section 10(23C) of the Income-tax Act, 1961—Exemption— The burden lies upon the Revenue to bring on record the evidence to rebut the claim of the assessee trust and to establish that the activities carried out and the expenditure incurred by the Assessee Trust could not be related to the educational activities of the assessee Trust by any stretch of imagination and no such exercise of either bringing the evidence on record or controverting or rebutting the evidence produced by the Assessee before the Chief Commissioner appears to have been undertaken by the learned Chief Commissioner- A mere reference to the expenditure incurred and the Head of expenditure in question while rejecting the Application under section 10(23C)(vi) of the Act is not enough to reject the Application under the provisions of the Act. - KAMARAJ EDUCATIONAL TRUST V/s CHIEF CIT - [2020] 427 ITR 074 (MAD)