TMI Blog2006 (5) TMI 68X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessing Officer relied upon investments made by the respondent in three different companies - surplus funds available with the assessee could be suitably invested whether by way of fixed deposit in a bank or financial institution or in stock market to earn profit which would in turn be available to the society for being utilised to pursue its educational purposes. Inasmuch as the assessee had in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under the provision mentioned above on the ground that the assessee was a profit making organisation and that the same did not exist solely for educational purpose. In support, the Assessing Officer relied upon investments made by the respondent in three different companies of the Birla group, namely, Kesoram Industries K. Ltd., Padmavati Raje Cotton Mills and Rajeshwari Polyfil Ltd., for the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1982] 136 ITR 445 (Cal), Gujarat State Co-operative Union v. CIT [1992] 195 ITR 279 (Guj) and Secondary Board of Education v. ITO [1972] 86 ITR 408 (Orissa). Reliance was also placed upon Circular No. 712, dated July 25,1995, issued by the Government wherein it was clarified that section 10(22) did not impose any restriction regarding the mode of investment of the funds. The additions made by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he surplus funds available with the assessee could be suitably invested whether by way of fixed deposit in a bank or financial institution or in stock market to earn profit which would in turn be available to the society for being utilised to pursue its educational purposes. Inasmuch as the assessee had in the instant case invested a part of its surplus funds for purchase of rights and bonus share ..... X X X X Extracts X X X X X X X X Extracts X X X X
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