https://www.taxtmi.com/caselaws?id=40269 Section 10(22) was construed as exempting only a university or educational institution existing solely for educational purposes and not for profit, and the majority held that some educational activity in India was required for the exemption to apply. A branch engaged in printing, publishing and sale of books was treated as a commercial establishment rather than an exempt educational institution, and the source of income was held not to be decisive. On that footing, exemption was denied. The dissent took the view that the provision contained no territorial limitation and that a foreign university branch satisfying the statutory description could qualify. en-us Wed, 24 Jan 2001 00:00:00 +0530 Wed, 07 Jan 2026 14:36:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=40269 Section 10(22) was construed as exempting only a university or educational institution existing solely for educational purposes and not for profit, and the majority held that some educational activity in India was required for the exemption to apply. A branch engaged in printing, publishing and sale of books was treated as a commercial establishment rather than an exempt educational institution, and the source of income was held not to be decisive. On that footing, exemption was denied. The dissent took the view that the provision contained no territorial limitation and that a foreign university branch satisfying the statutory description could qualify. Case-Laws Income Tax Wed, 24 Jan 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=40269