Educational institution exemption under section 10(22) applied where the society existed solely for education and not profit.

An educational society running an institution was treated as an educational institution existing solely for educational purposes and not for profit. The Tribunal applied the same statutory interpretation as in an earlier identical decision and held that the assessee satisfied the requirement for exemption of its income under section 10(22) of the Income-tax Act, 1961. The reference was answered in favour of the assessee and against the Revenue on that basis.

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Issues: Whether the assessee, an educational society running an educational institution, was entitled to exemption of its entire income under section 10(22) of the Income-tax Act, 1961.

Analysis: The reference arose from assessment year 1976-77. The Tribunal had held that the assessee satisfied the statutory requirement of being an educational institution existing solely for educational purposes and not for profit. The matter was treated as covered by the earlier decision of the Court on identical facts, and the same statutory interpretation was applied.

Conclusion: The assessee was entitled to exemption under section 10(22) of the Income-tax Act, 1961, and the reference was answered in favour of the assessee and against the Revenue.

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