1994 (9) TMI 56

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... the Income-tax Act, 1961, relate to the assessment years 1983-84, 1984-85 and 1985-86. The question raised for consideration is whether the assessee is entitled to exemption under section 10(22A) of the Act. The same question arose for consideration in the years 1981-82 and 1982-83 and this court in the decision in CIT v. Pulikkal Medical Foundation (P.) Ltd. [1994] 210 ITR 299 ; [1993] KLJ (Tax .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... l as the questions cover all the aspects of the questions raised by the Revenue before the Tribunal, namely : " l. Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that it cannot be said that profit motive is involved in the activities of the assessee-company ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was ri .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... private gain in the year of account, the assessee is entitled to exemption under section 10(22A) ? " The Income-tax Appellate Tribunal, Cochin Bench, is, therefore, directed to state a case and refer the aforesaid questions of law for the opinion of this court under section 256(2) of the Income-tax Act, 1961. Communicate a copy of this judgment under the seal of this court and the signature of .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X