https://www.taxtmi.com/caselaws?id=21194 HC held that the assessee-trust was not entitled to exemption under s.10(22) of the Income-tax Act. To qualify, an assessee must be an educational institution or establishment primarily engaged in educational activities involving actual imparting of education through normal schooling or classes, with a teacher-taught relationship. Incidental activities such as grants, scholarships, or investments qualify only if they are ancillary to such core educational activity. The trust, founded to establish a school or college for Zoroastrian students, had since 1956 only been granting scholarships without running any educational institution or conducting classes. Consequently, it was not an educational institution for s.10(22) purposes, and the question was answered in favour of the Revenue. en-us Mon, 17 Aug 1992 00:00:00 +0530 Thu, 11 Dec 2025 15:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21194 HC held that the assessee-trust was not entitled to exemption under s.10(22) of the Income-tax Act. To qualify, an assessee must be an educational institution or establishment primarily engaged in educational activities involving actual imparting of education through normal schooling or classes, with a teacher-taught relationship. Incidental activities such as grants, scholarships, or investments qualify only if they are ancillary to such core educational activity. The trust, founded to establish a school or college for Zoroastrian students, had since 1956 only been granting scholarships without running any educational institution or conducting classes. Consequently, it was not an educational institution for s.10(22) purposes, and the question was answered in favour of the Revenue. Case-Laws Income Tax Mon, 17 Aug 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21194