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Interpretation of section 10(22) of the Income-tax Act, 1961 regarding educational institutions' eligibility for tax benefits. Analysis: The judgment involves the interpretation of section 10(22) of the Income-tax Act, 1961, concerning the eligibility of educational institutions for tax benefits. The Revenue filed five appeals challenging the Income-tax Appellate Tribunal's decision allowing the benefit of section 10(22) to the respondent/assessee. The Tribunal's order highlighted that the assessee operated multiple schools with numerous teachers and students, engaging in charitable activities primarily focused on education. However, a question arose whether the institution existed solely for educational purposes. The Assessing Officer contended that the presence of a dispensary, orphanage, and church indicated activities beyond education. In contrast, the CIT and the Tribunal disagreed, emphasizing that these ancillary activities supported the main educational mission. Notably, the nuns teaching at the schools donated their salaries back to the institution, which then provided for their upkeep. Additionally, the orphanage under the assessee's management catered to abandoned children, focusing on their education without engaging in adoption services. The Tribunal concluded that the primary function of the assessee was educational, with the ancillary services like the dispensary, church, and orphanage complementing rather than detracting from this core mission. The judgment emphasized that these activities were essential for the well-being of students, teachers, nuns, and abandoned children under the institution's care. The court concurred with the Tribunal's findings, noting that no evidence suggested profit-seeking motives or non-educational purposes behind the assessee's operations. Ultimately, the court found no substantial legal question arising from the case, leading to the dismissal of the appeals. The judgment underscored the importance of ancillary services in supporting the core educational activities of the institution, affirming the eligibility of the assessee for the tax benefits under section 10(22) of the Income-tax Act, 1961.
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