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I.T.Act and was denied exemption u/s.11 of the Act which was under challenge before the Hon'ble High Court. The case of Gujarat State Co-operative Union (cited supra) also is with regard to claim of exemption u/s.10(22) of the Act and the Hon'ble Gujarat High Court in the said case has held as under:
Held, that the assessee was a society for diffusion of a certain branch of knowledge, namely, knowledge of the co-operative movement in various fields governing human life and the activities for the purpose were carried out in an organized and systematic manner by conducting regular courses for imparting instruction and training on various subjects included int eh curricula as was reflected from the list of its activities. The object of running a printing press had to be read in the context of the object of publishing periodicals, books, pamphlets and literature. It was part of the educational activities of the assessee-co-operative union. Having regard to its objects and the nature of its activities, it was an educational institution existing solely for educational purposes. It was entitled to exemption under section 10(22) for the assessment years 1972-73 to 1977-78 . Therefore, there is clear distinction on facts from the case before us. Therefore, the decisions relied upon by the assessee are clearly distinguishable and are thus not applicable to the case before us.
As regards the claim of the assessee that it should be considered as carrying on activities of “Advancement of any other object of General Public Utility”, we find that the CIT (E) has not gone into this aspect of the issue at all. It is for the CIT (E) to examine all the aspects of charitable activity claimed by the assessee when the assessee has applied for registration u/s 12A of the Act. In view of the same, we deem it fit and proper to remand the issue back to the file of the CIT (E)