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2005 (6) TMI 17 - HC - Income Tax"Whether, on the facts and in the circumstances of the case, the assessee was entitled to exemption under section 10(22) on interest earned on surplus funds of the school (run by the assessee-trust) for the assessment years 1979-80 and 1980-81?" - It is, thus, obvious that granting exemption to the income of the educational institutions is to enable such institutions to utilise the moneys available with them for the purpose of running the educational institutions. The source from which the moneys are received is of no consequence, what is relevant is the application of income. So long as the income of the institution, which solely exists for educational purpose and not for earning profit, is applied for the educational purpose, such income of the institution is exempted under section 10(22) of the Act. The question referred is, thus, answered in the affirmative, i.e., in favour of the assessee and against the Revenue
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