SATYA EDUCATION SOCIETY ,HARYANA vs. EXEMPTIONS WARD ROHTAK , HARYANA

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ITA 1016/DEL/2026Status: DisposedITAT Delhi29 June 2026AY 2027-284 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(Exemptions) interpreted the term 'education' too narrowly, ignoring available judicial precedents. The assessee was given an opportunity to present all facts to the CIT(Exemptions) for a fresh adjudication.

What were the facts?

The assessee, Satya Education Society, applied for registration under Section 12A(1)(ac)(ii) of the Income Tax Act. The CIT(Exemptions) rejected the application, holding that the society's activities, primarily computer courses, were not educational in nature according to a narrow interpretation.

What were the issues?

Whether the activities of the assessee, including conducting computer courses and charging fees, constitute 'education' as per Section 2(15) of the Income Tax Act for the purpose of registration under Section 12A(1)(ac)(ii).

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(ii),Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “H” NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI SANJAY AWASTHI

For Appellant: Ms. Shruti Khandelwal, Adv. (Virtual)
For Respondent: Shri Bhopal Singh, CIT DR
Hearing: 29.06.2026

ITA No. 1016/Del/2026 SATYA EDUCATION SOCIETY, HARYANA IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “H” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA No.1016/Del/2026 Assessment Year: 2027-28 SATYA EDUCATION SOCIETY, Vs. COMMISSIONER OF INCOME TAX Old Kachery Chowk, Behind city Plaza (EXEMPTIONS), Chandigarh, Complex, Hisar, Haryana, 125001. Exemptions Ward, Rohtak, PAN No. AACAS2648P Haryana, 124001. Appellant Respondent Assessee by Ms. Shruti Khandelwal, Adv. (Virtual) Revenue by Shri Bhopal Singh, CIT DR Date of hearing: 29.06.2026 Pronouncement on 29.06.2026 O R D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. In this case, the Ld. CIT(Exemptions), Chandigarh, vide order dated 09.12.2025 has rejected the application for registration filed by the assessee u/s 12A(1)(ac)(ii) of the Income Tax Act, 1961 (hereafter as “the Act”). It is seen from the impugned order that the Ld. CIT(E) has held that the assessee-society is not carrying out activities which are educational in nature. It is seen that there is some fact finding on pages 8 to 12 of the impugned order through which it has been held that the assessee is conducting computer courses at a small level and charging fees for the same. Thereafter, the Ld. CIT(E) has held that “education” would imply systematic instruction, school or training by an Institution

ITA No. 1016/Del/2026 SATYA EDUCATION SOCIETY, HARYANA which is affiliated to Boards & Universities, etc. (para 4.1 at page 12 of the impugned order). It is also seen that the assessee has not found to be conforming to this particular interpretation of “education” and thereby the application has been rejected.

2.

The aggrieved assessee has approached the ITAT with grounds challenging this action on merit as also the fact that the order is not speaking, was passed with inadequate opportunity of being heard and was also passed ignoring the fact that the assessee already had a registration u/s 12AB of the Act dated 06.10.2021.

3.

The Ld. AR stated that the Ld. CIT(Exemption) had not understood the concept of “education” and thereafter had adversely dealt with the matter before him in spite of the fact that some documents were provided to him. It was the submission that the assessee needed another opportunity to establish the facts of his case and therefore it was prayed that the matter may be remanded back to the file of Ld. CIT(Exemption).

3.1 The Ld. DR relied on the impugned order and stated that the Ld. CIT(Exemption) had given considerable details as to why the assessee did not deserve any registration u/s 12A of the Act.

4.

We have carefully considered the rival submissions and have gone through the records before us. It is seen that the Ld. CIT(Exemption) has understood the term “education” as mentioned in section 2(15) of the

ITA No. 1016/Del/2026 SATYA EDUCATION SOCIETY, HARYANA Act in a narrow sense. We find that in spite of there being considerable judicial literature available on what constitutes “education”, the Ld. CIT(Exemption) has chosen to substitute his own understanding of the concept on the facts of the present case. It is felt that the assessee needs to present all the facts that are available with him so that the Ld. CIT(Exemption) is able to appreciate the extent of activities being performed by the assessee and thereafter a reasonable view would be possible to adopt. For this purpose, we set aside the impugned order and remand this matter back to the file of Ld. CIT(Exemption) for fresh adjudication. The Ld. CIT(Exemption) would give adequate opportunity of being heard and the assessee would avail of such opportunities to make an extensive representation before him.

5.

In the result, appeal is partly allowed for statistical purposes.

Order pronounced in the open court on 29.06.2026 Sd/- Sd/- (SATBEER SINGH GODARA) (SANJAY AWASTHI) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 30.06.2026 *Kavita Arora, Sr. P.S. Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT 3

ITA No. 1016/Del/2026 SATYA EDUCATION SOCIETY, HARYANA ASSISTANT REGISTRAR ITAT, NEW DELHI

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