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TMI Blog2022 (7) TMI 746X X X X Extracts X X X X X X X X Extracts X X X X ..... lete Objects 7 and 10, cannot record a finding against the assessee. So far as Object No.4 is concerned, we are of the view that assisting Banking Institutions in the matters such as appraisal programmes, conducting morale and productivity studies etc., also fall within the category of education. It is not in dispute that the assessee is a Staff Training College for Bank employees. Therefore, in our considered view, assessee must be construed as an Educational Institution because the main object is to train the Bank Officials. The question of law raised by the assessee is answered in its favour and against the Revenue. - I.T.A No.41 OF 2017 - - - Dated:- 8-7-2022 - HON BLE MR. JUSTICE P.S. DINESH KUMAR AND HON BLE MR. JUSTICE C.M. POONA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... educational purposes because, object No.4 provides for assisting Banking Institutions in the matters such as appraisal programmes, conducting morale and productivity studies etc and object No.7 provides for giving consultancy services. 5. He further submitted that the assessee has written to the DDIT (The Deputy Director of Income-tax (Exemptions) Circle 17(2), Bangalore) as back as August 16, 2008 stating that objects No.7 and 10 of the MoA were deleted and a copy of the amended Memorandum was furnished and approval was sought to amend the MoA. But the Income Tax Department has not granted the approval sought. 6. He urged that the assessee mainly runs the Staff Training College. It has not involved itself with any other activity. H ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent; 10. A copy of the letter dated August 16, 2008, written by the assessee to the DDIT seeking approval to amend the MoA and to delete Objects No. 7 and 10, is produced as Annexure-J. We have carefully perused it. The said letter has been received in the Office of DDIT, in 2008. The application in Form No.56B has been submitted on September 26, 2014 seeking exemption under Section 10(23C)(vi) of the IT Act. 11. The Commissioner has held that in order to qualify for exemption, applicant institution must be solely for educational purposes but objects No. 7 and 10 are not strictly for educational purposes. The ITAT has reiterated Commissioner's view in para 7 of its order. It has distinguished the Judgment in Vidya Vikas Vihar, o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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