COMMISSIONER OF INCOME TAX Vs. DEVI EDUCATIONAL INSTITUTION

JUDGEMENT

(1.) IN T.C. No. 477 of 1978, at the instance of the Revenue, the following question has been referred by the INcome-tax Appellate Tribunal to this court for its opinion :

(2.) IN T.Cs. Nos. 486 and 487 of 1978, again at the instance of the Revenue, the following common question has been referred to this court for its opinion :

(3.) THUS, the main and substantial question for consideration in these cases is whether the assessee-society is an educational institution entitled to claim exemption under s. 10(22) of the Act. As already stated, the Tribunal had held that the objects of the society are substantially educational, and the society having taken due and irreversible steps for the establishment of an institution for carrying on the said educational objects set out in the memorandum of association, the society should be taken to be an educational institution contemplated by s. 10(22). In support of the said view, the Tribunal has followed its own earlier judgment in I.T.A. Nos. 720 of 1972-73 and 383 of 1973-74 dated April 22, 1974.