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Issues:
1. Whether the assessee is entitled to exemption under section 10(22) of the Income-tax Act. The judgment dealt with the issue of whether an assessee Trust was eligible for exemption under section 10(22) of the Income-tax Act. The Trust was established in 1952 with the objective of setting up medical colleges and hospitals for medical education. The Income-tax Officer rejected the claim for exemption as the medical colleges had been transferred to another Trust, and during the relevant year, the assessee Trust was not running any educational institution. The Commissioner of Income-tax (Appeals) held that the income was eligible for exemption under section 10(22), leading to the revenue's appeal against this decision. The main argument presented by the Trust was that it had a research wing in the field of medicine, which should qualify as an educational purpose under section 10(22). The Trust contended that even though it was not operating a medical college during the relevant year, its research activities should be considered educational. The revenue argued that research is not equivalent to education and, therefore, the Trust could not be classified as an educational institution. The Tribunal analyzed the definition of "education" as per the Income-tax Act and relevant case law. It referred to the Supreme Court's decision in Sole Trustee, Loka Shikshana Trust v. CIT, which defined education as systematic instruction or training for developing knowledge, skill, mind, and character. The Tribunal also cited the Rajasthan High Court's ruling in CIT v. Maharaja Sawai Mansinghji Museum Trust, emphasizing the broad interpretation of education for the purpose of section 10(22). Furthermore, the Tribunal highlighted the Karnataka High Court's precedent in CIT v. Academy of General Education, stating that an assessee claiming section 10(22) benefits need not necessarily be a traditional school or college. The main objective must be related to education, as established in the case of Ecumenical Christian Centre v. CIT. The Tribunal also referenced a Gujarat High Court decision where a co-operative society union engaged in educational activities was entitled to exemption under section 10(22). In the case at hand, the Tribunal found that the Trust's primary purpose was to aid and cooperate in the field of education, particularly in medicine. Despite transferring the medical colleges, the Trust maintained a research wing that provided systematic instruction and training in various medical disciplines. The research fellows associated with the Trust acquired academic qualifications through super specialization in medicine, indicating an educational aspect to the Trust's activities. Consequently, the Tribunal upheld the Commissioner (Appeals)'s decision to grant exemption under section 10(22) to the Trust, dismissing the revenue's appeal.
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