TMI Blog2012 (3) TMI 263X X X X Extracts X X X X X X X X Extracts X X X X ..... at 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 semina ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d is whether the Tribunal was justified in holding that the respondent was entitled to claim exemption u/s 10(23C)(iiiad) for the first time at the appellate stage. We have heard the learned Standing Counsel appearing for the appellant and we have also gone through the orders of the Tribunal. 2. The first question raised is whether a seminary coaching and training students for priesthood is an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tholic Church at Thiruvananthapuram where several students undergo coaching and training for priesthood. Freedom to practice and propagate religion is a right conferred under Article 25 of the Constitution. Propagation of religion necessarily involves education and training of young generation on religious matters and unless the same is systematically done religious beliefs and practices cannot be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on in any particular subject or in any manner whatsoever. So much so, 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. In the case of seminary, students on completion of their studies are made priests who head the churches as religious leaders practising and propag ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llowed the claim on merits which is contested by the Revenue in this appeal. 5. The Hon'ble Supreme Court in National Thermal Power Co. Ltd. v. Commissioner of Income Tax . 229 ITR 383 held that a pure question of law can be raised at any stage of the proceedings under the I.T. Act. The ground raised in appeal by the assessee based on 10 (23C)(iiiad) is certainly a pure question of law and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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