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2022 (7) TMI 746 - KARNATAKA HIGH COURTExemption u/s 10(23C)(vi) - Whether Tribunal erred rejecting the application for exemption u/s 10(23C)(vi) of the Act without considering the vast definition that the word "education" embraces although there being no specific definition for "education" under the Income Tax Act of 1961? - HELD THAT:- In the case on hand, it is not in dispute that assessee has written to the DDIT to permit deletion of Objects No. 7 and 10. According to the Commissioner, Objects No. 4 and 7 disentitle the assessee from exemption. Shri. Parthasarathi is right in his submission that the Department not having granted permission to delete Objects 7 and 10, cannot record a finding against the assessee. So far as Object No.4 is concerned, we are of the view that assisting Banking Institutions in the matters such as appraisal programmes, conducting morale and productivity studies etc., also fall within the category of education. It is not in dispute that the assessee is a Staff Training College for Bank employees. Therefore, in our considered view, assessee must be construed as an Educational Institution because the main object is to train the Bank Officials. The question of law raised by the assessee is answered in its favour and against the Revenue.
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