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2022 Supreme(SC) 1075

UDAY UMESH LALIT, S. RAVINDRA BHAT, PAMIDIGHANTAM SRI NARASIMHA
New Noble Educational Society – Appellant
Versus
Chief Commissioner of Income Tax-1 – Respondent


Advocates appeared:
For the Appellant(s) : Mr. Nikhil Swami,Adv. Mrs. Prabha Swami, Adv.
For the Respondent(s): Ms. Pushpa Kishore, Adv.

Table of Content
1. the significance of education in law (Para 1 , 2)
2. rejection of appellants' registration claims under it act (Para 3 , 4)
3. arguments against section 10(23c)(vi) interpretation (Para 5 , 6 , 7)
4. details of court's analysis of the law regarding educational institutions (Para 8 , 9 , 10)
5. interpretation of 'solely' in educational context (Para 30 , 32 , 34)
6. final ruling and implications for educational institutions (Para 76 , 78)

JUDGMENT :

1. It has been said that education is the key that unlocks the golden door to freedom.1[An aphorism common to all faiths. Proverb 4:13 states, “Take hold of instruction, do not let go. Guard her, for she is your life.” The Pavamana Mantras (purifying mantras) appealing to be taken from darkness to light in Brihadaranyaka Upanishad, as part of verse 1.3.28 too emphasizes the value of knowledge and education, “Lead me from the darkness of ignorance to the light (of knowledge).” Surah Al-Baqarah, gives an important interpretation about learning, “He gives knowledge and wisdom to whomever He wills and to whomsoever knowledge is given, much good has been given.”] In Avinash Mehrotra v. Union of India , (2009) 6 SCC 398, this cour


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