Sec. 12AA Training in rock climbing, mountaineering, bag-packing, kayaking, sailing and rafting is educational activity

 The assessee is engaged in the activities of rock climbing and mountaineering, bag-packing, kayaking, sailing and rafting. It says that it is one of the world^‟s biggest outdoor skill trainer and its parent is headquartered in the USA. It offered courses in the Himalayan by instructing. It is submitted that it not only teaches the outdoor skills but also keeps the course dynamic with evolving situations used as case s

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