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2012 (3) TMI 263 - HC - Income TaxEducational institution – whether "Seminary" teaching students for priesthood is an educational institution entitled to exemption from tax u/s 10(23C)(iiiad) – whether such exemption can be granted at the appellate stage – Held that:- There is nothing to indicate that S.10(23C)(iiiad), requires the educational institutions to impart education in any particular subject or in any manner whatsoever. The term 'education' should enjoy a wide connotation covering all kinds of coaching and training carried on in a systematic manner leading to personality development of an individual. Thus, we hold that religious teaching in the seminary is also education and seminary is therefore an "educational institution" entitled for exemption u/s 10 (23C)(iiiad). In view of decision in case of National thermal Power Corporation Vs. CIT (1996 - TMI - 5626 - Supreme Court), pure question of law can be raised at any stage of the proceedings – Decided in favor of assessee.
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