1994 (3) TMI 133

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..... me during the year. The said income was claimed to be exempt under section 10(22). The Income-tax Officer rejected the claim and brought the income to charge. The assessee preferred an appeal and the Commissioner of Income-tax (Appeals) held that the Income was eligible for exemption under section 10(22). The revenue is in appeal objecting to that order. 4. The Trust had established medical colleges. During the year of account those medical colleges had been transferred to Dr. T.M.A. Pai Foundation, another Trust. After the said transfer, there was no college in the administration, control or management of the assessee-Trust. In the view of the Income-tax Officer, the assessee-Trust had not carried out any activity set out in section 10(2 .....

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..... ained, then one can attribute the same meaning to the word "education" found in other sections, including section 10(22), with grammatical variation. The high watermark is pointed out by the Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 to explain the sense in which the word "education" used in section 2(15). As per that, "education" means systematic instruction, schooling or training given to persons in pursuit of education for the purpose of training and developing the knowledge, skill, mind and character. 8. The Rajasthan High Court has pointed out in the case of CIT v. Maharaja Sawai Mansinghji Museum Trust [1988] 169 ITR 379 that the pronouncement of the Supreme Court in the case of Sole Tr .....

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..... , no doubt, been transferred to Dr. T.M.A. Pai Foundation in the earlier year. But the assessee had a research wing. To repeat the submission of Shri Puniha, giving aid or assistance in the field of research is not "education". We have on record a catalogue brought about by the Research and Publications Division of Kasturba Medical College Trust (assessee) for the year 1982-83. Research wings have been formed in many branches of medical science. Research papers are printed and published. There is a research journal section also. Three persons who are professors and heads of department are guides in the research scheme. They are : Dr. T.N. Pattabiraman, Dr. P.S. Shivananda and Dr. V. Chacko, as can be seen from the paper book. There are pupi .....

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