DY. COMMISSIONER OF INCOME TAX(EXEMPTIONS), CIRCLE-1, BENGALURU, BANGALORE vs. RASHTREEYA SIKSHANA SAMITHI TRUST, BANGALORE

ITA 1766/BANG/2025Status: DisposedITAT Bangalore23 June 2026AY 2016-1733 pages
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What were the facts?

The assessee, a trust running educational institutions, collected 'development fees' from students, which the AO considered to be capitation fees and indicative of a profit motive. The AO also questioned the reinvestment of compensation from compulsory acquisition of property.

What did the Tribunal hold?

The Tribunal held that the collection of 'development fees' was not necessarily indicative of a profit motive and that the reinvestment of compensation for compulsory acquisition of property into new capital assets met the conditions of Section 11(1A) of the Income Tax Act.

What were the issues?

Whether the collection of 'development fees' by an educational trust indicates a profit motive, disqualifying it for exemption, and whether reinvestment of compensation from compulsory acquisition of property qualifies for exemption under Section 11(1A).

Which sections of the Income-tax Act were involved?

Section 11,Section 12,Section 11(1A),Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Shri Bhardwaj Sheshadri and Shri Sandeep Hilgol
For Respondent: Shri N.S Shashidhara, CIT (DR)
Hearing: 10.06.2026Pronounced: 23.06.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

These appeals are filed by the assessee and the Revenue against the order passed under section 250 of the Income Tax 1961 pertaining to A.Ys. 2014-15 to 2016-17 at National Faceless Appeal Centre-NFAC, Delhi.

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The order continues below.

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