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The High Court of Gujarat ruled against the assessee, Sheth Sorabji Nasarwanji Parekh, in a case involving exemption under section 10(22) of the Income-tax Act, 1961. The court held that the trust was not entitled to total exemption as it had not established any educational institution or carried out educational activities since 1956. The Income-tax Appellate Tribunal's decision in favor of the assessee was overturned. The judgment was delivered by M. B. Shah J. and M. Panchal J. The court's decision was based on a previous case involving the same assessee for the assessment year 1972-73.
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