This is appeal by Revenue for asst. yr. 1980-81 against order of AAC. only point for decision in this appeal is whether income of assessee society registered under societies Registration Act, XXI of 1960 is exempt under s. 10(22) of IT Act, 1961. constitution of assessee is included in paper book. Para 2 of said constitution sets out objects of assessee. objects so laid down are clearly indicative of fact that assessee was established to extend educational facilities to children and to achieve such objective, assessee society established two institutions, namely. Bal Mandir and Bal Madhyamik Vidhyalaya. ITO, however, taxed income of assessee. On appeal, AAC relied on Katra Education Society vs. ITO (supra) and Additional CIT vs. Aditanar Educational Institution (supra) in support of his view, inter alia. Aggrieved, Revenue has come up in appeal to Tribunal. We have heard Shri Singh, ld. Departmental Representative and Shri M. P. Sharma, ld. counsel for assessee. Shri Singh, referring to provisions of sub-s. 22 of s. 1 0 , argues that assessee-society simply engaged two educational institutions and that it is not educational institutions itself within meaning o f sub-s. (22) of s. 10. He argues that exemption can be claimed only by educational institutions and not by any other institution, which ran or managed educational institution. We have carefully gone through two above mentioned authorities and are of view that case of assessee is fully supported by them. Similar question came up for consideration before Hon ble Allahabad High Court in 1977 CTR (All) 211: (1978) 111 ITR 420 (All). then almost same view was taken by Revenue. But, Allahabad High Court held there is no reason why educational society cannot be regarded as educational institution if that is running educational institution. In (1979) 1818 ITR 235 (Mad), facts were that assessee had set up colleges to impart education. contention of Revenue was that institution, in order to qualify for exemption under s. 10(22), should itself be educational institution and that it was not enough if it ran education institution. It was contended that assessee could assist colleges and that in case it merely rendered assistance, it would be in nature of financial body, which did not itself impart education. Then Madras High Court fully agreed with Allahabad High Court (1977) CTR (All) 211: (1978) 111 ITR 420 (All). It was observed that assessee has come into existence for purpose of establishing, running, managing or assisting colleges, schools and other educational organisations and in pursuance of its objects, assessee had established college. Madras High Court then observed on P. 240 that medium through which assessee could effectuate its objects is college and by employing this medium, assessee imparts education. These authorities are squarely applicable to case of assessee, which also ran two institutions for imparting education to children, which was sole primary object of institution. instant assessee-society, in our view, cannot be directed from educational institutions, which are being run by former. Whereas assessee-society is administrative body, institutions being actually run by it impart education to children and, therefore, exemption under s. 10(22) cannot be refused merely on ground that assessee itself is not educational institution, inasmuch as, it actually does not impart education. It is too narrow interpretation, which Revenue sought to put on s. 10(22). In our view, assessee is fully covered by expression "other education institution" occurring in s. 10(22). appeal is, therefore, dismissed. *** INCOME TAX OFFICER v. BAL HIT KARI SAMITY