Institutional identity and annual receipt computation under section 10(23C) required examination; appeal admitted for consideration.

The Court treated the dispute as turning on whether the junior high school and intermediate college were legally separate institutions or merely different sections of one institution for exemption under section 10(23C), and whether annual receipts were correctly computed for the statutory threshold. It noted that the society was a distinct legal entity, but the status of the institutions, their recognition under different educational enactments, and the effect of the exemption provisions had not been fully examined below. On that basis, the Court found the substantial questions of law fit for consideration and admitted the appeal, directing notice to issue.

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Issues: Whether the appeal raised substantial questions of law warranting admission; whether the legal identity of the educational institution or institutions, and the manner of computation of annual receipts for exemption under section 10(23C), required examination.

Analysis: The order records that the society was a distinct legal entity, but the tax treatment depended on whether the junior high school and the intermediate college were legally separate institutions or merely different sections of one institution. It also notes that the authorities below had not fully examined the status of the institutions, the impact of recognition under different educational enactments, and the relevance of the statutory provisions governing exemption and the annual receipt threshold. On that basis, the Court held that the legal issues raised were fit for consideration.

Conclusion: The appeal was admitted and notice was directed to be issued, indicating that the substantial questions of law would be considered on merits.

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