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M/S Queen'S Educational Society vs Commr.Of Income Tax on 16 March, 2015

25.Hence, in view of the law laid down by the Hon'ble Apex Court in Queen's Educational Society vs. CIT (supra), we are of the opinion that no fault can be found in utilization of surplus fund by the assessee for the purposes of buying the buses / transportation. Admittedly, the buses are ferrying to 66 villages and transporting to the students to the school. In the absence of buses the quality education would be a pipedream and would not be a reality. In our considered opinion the education per se cannot be given a pedantic or narrow interpretation and it should be given the wide interpretation so that all the ancillary but necessary activity would form the part of education. The overall development of student should be the aim and object of the student and it should not be restricted to academics but it 17 I.T.A. No. 583/Asr/2016 should also take care of sports, scientific temperament, psycological development character building, nationalism, civic sense etc. In our view in the absence of necessary transport facility, the students will not be able to attend school regularly and punctually. Therefore, the provision for transportation is sine qua non and is integral part of imparting education. In view of the above, the objection of the CIT(E) is devoid of any merit.
Supreme Court of India Cites 37 - Cited by 180 - R F Nariman - Full Document
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