25. In Commissioner of Income Tax v. M.P. Rajya Pathya Pustak Nigam

226 CTR 497High Court2009#9545 most cited

What is 25. In Commissioner of Income Tax v. M.P. Rajya Pathya Pustak Nigam authority for?

An assessee engaged in publishing and selling school textbooks does not cease to carry on the activity of education merely because it generates profits. The interpretation of 'education' under Section 2(15) is key, and profitability does not negate the educational nature of the activity.

11

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2017 to 2025.

Also referred to as

Commissioner of Income Tax v. M.P. Rajya Pathya Pustak Nigam · 2009 · 226 CTR 497 · Section 2(15) · Section 11 · Section 12 · education · charitable purpose · profit from activity · publishing school textbooks

Sections most often in play

Section 11Section 12Section 2(15)

Judgments citing 25. In Commissioner of Income Tax v. M.P. Rajya Pathya Pustak Nigam

ACIT Circle-1(1) (E)New Delhi, Delhi vs. Delhi Bureau of Text Books, Delhi

In the result, both the appeals of the Revenue are dismissed

ITA 1115/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalacit, Delhi Bureau Of Text Books Circle-1(1), 25/2 Institutional Area, New Delhi. Vs. Pankha Road, D Block, Janak Puri, Delhi-110058 Pan-Aaatd4122G (Appellant) (Respondent) Assessee By None Department By Ms. Suman Malik, Cit-Dr Date Of Hearing 02/06/2025 Date Of Pronouncement 02/06/2025 O R D E R Per Manish Agarwal, Am: Both The Appeals Are Filed By The Revenue Against The Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Appeal No. Cit(A), Delhi-40/10313/2018-19 & Appeal No. Nfac/2016- 17/10028873 For Assessment Year 2016-17 & 2017-18 Respectively.

Section 11Section 12

…67 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 408 (Ori), Institution of Chartered Accountants of India vs. Director General of Income Tax (Exemptions) (2012) 347 ITR 99 (Del), Commissioner of Income Tax vs. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP), General of Income Tax (Exemptions) (2014) 362 ITR 436 (Del), examined the question of interpretation placed on the word 'education' occurring in section 2(15) of the Act, and reached the conclusion that merely because the assessee had generated profits out of the activity of publishing and selling of School text books, it cannot be said tha…

ACIT Circle-1(1) (E) New Delhi, Delhi vs. Delhi Bureau of Text Books, Delhi

In the result, both the appeals of the Revenue are dismissed

ITA 1114/DEL/2024[2016-17]Status: DisposedITAT Delhi18 Jun 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalacit, Delhi Bureau Of Text Books Circle-1(1), 25/2 Institutional Area, New Delhi. Vs. Pankha Road, D Block, Janak Puri, Delhi-110058 Pan-Aaatd4122G (Appellant) (Respondent) Assessee By None Department By Ms. Suman Malik, Cit-Dr Date Of Hearing 02/06/2025 Date Of Pronouncement 02/06/2025 O R D E R Per Manish Agarwal, Am: Both The Appeals Are Filed By The Revenue Against The Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Appeal No. Cit(A), Delhi-40/10313/2018-19 & Appeal No. Nfac/2016- 17/10028873 For Assessment Year 2016-17 & 2017-18 Respectively.

Section 11Section 12

…67 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 408 (Ori), Institution of Chartered Accountants of India vs. Director General of Income Tax (Exemptions) (2012) 347 ITR 99 (Del), Commissioner of Income Tax vs. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP), General of Income Tax (Exemptions) (2014) 362 ITR 436 (Del), examined the question of interpretation placed on the word 'education' occurring in section 2(15) of the Act, and reached the conclusion that merely because the assessee had generated profits out of the activity of publishing and selling of School text books, it cannot be said tha…

DCIT(E), Circle-1(1), New Delhi vs. Delhi Bureau of Text Books, New Delhi

The appeal of the Revenue is dismissed

ITA 7075/DEL/2018[2013-14]Status: DisposedITAT Delhi27 Sept 2021AY 2013-14

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Dr. Maninder Kaur, Sr.D.RFor Respondent: Ms. Anubha Malwani, CA
Section 10(23)(c)Section 11Section 12Section 12ASection 2

…67 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 408 (Ori), Institution of Chartered Accountants of India vs. Director General of Income Tax (Exemptions) (2012) 347 ITR 99 (Del), Commissioner of Income Tax vs. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP), General of Income Tax (Exemptions) (2014) 362 ITR 436 (Del), examined the question of interpretation placed on the word 'education' occurring in section 2(15) of the Act, and reached the conclusion that merely because the assessee had generated profits out of the activity of publishing and selling of School text books, it cannot be said tha…

ACIT(E), Circle-1(1), New Delhi vs. Delhi Bureau of Text Books, New Delhi

In the result, all the appeals of the revenue are dismissed

ITA 242/DEL/2018[2014-15]Status: DisposedITAT Delhi09 Dec 2020AY 2014-15

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 240/Del/2018 : Asstt. Year : 2011-12 Ita No. 241/Del/2018 : Asstt. Year : 2012-13 Ita No. 242/Del/2018 : Asstt. Year : 2014-15 Acit(E), Vs Delhi Bureau Of Text Books, Circle-1(1), 25/2, Institutional Area, Pankha New Delhi Road, D-Block, Janakpuri, New Delhi-110058 (Appellant) (Respondent) Pan No. Aaatd4122G Assessee By : Sh. Amit Kumar Gupta, Adv. Revenue By : Sh. Jagdish Singh, Sr. Dr Date Of Hearing: 24.11.2020 Date Of Pronouncement: 09.12.2020

For Appellant: Sh. Amit Kumar Gupta, AdvFor Respondent: Sh. Jagdish Singh, Sr. DR
Section 10Section 11Section 12ASection 2(15)

…67 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 408 (Ori), Institution of Chartered Accountants of India vs. Director General of Income Tax (Exemptions) (2012) 347 ITR 99 (Del), Commissioner of Income Tax vs. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP), General of Income Tax (Exemptions) (2014) 362 ITR 436 (Del), examined the question of interpretation placed on the word 'education' occurring in section 2(15) of the Ad, and reached the conclusion that merely because the assessee had generated profits out of the activity of publishing and selling of School text books, it cannot be said that…

ACIT(E), Circle-1(1), New Delhi vs. Delhi Bureau of Text Books, New Delhi

In the result, all the appeals of the revenue are dismissed

ITA 241/DEL/2018[2012-13]Status: DisposedITAT Delhi09 Dec 2020AY 2012-13

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 240/Del/2018 : Asstt. Year : 2011-12 Ita No. 241/Del/2018 : Asstt. Year : 2012-13 Ita No. 242/Del/2018 : Asstt. Year : 2014-15 Acit(E), Vs Delhi Bureau Of Text Books, Circle-1(1), 25/2, Institutional Area, Pankha New Delhi Road, D-Block, Janakpuri, New Delhi-110058 (Appellant) (Respondent) Pan No. Aaatd4122G Assessee By : Sh. Amit Kumar Gupta, Adv. Revenue By : Sh. Jagdish Singh, Sr. Dr Date Of Hearing: 24.11.2020 Date Of Pronouncement: 09.12.2020

For Appellant: Sh. Amit Kumar Gupta, AdvFor Respondent: Sh. Jagdish Singh, Sr. DR
Section 10Section 11Section 12ASection 2(15)

…67 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 408 (Ori), Institution of Chartered Accountants of India vs. Director General of Income Tax (Exemptions) (2012) 347 ITR 99 (Del), Commissioner of Income Tax vs. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP), General of Income Tax (Exemptions) (2014) 362 ITR 436 (Del), examined the question of interpretation placed on the word 'education' occurring in section 2(15) of the Ad, and reached the conclusion that merely because the assessee had generated profits out of the activity of publishing and selling of School text books, it cannot be said that…

ACIT(E), Circle-1(1), New Delhi vs. Delhi Bureau of Text Books, New Delhi

In the result, all the appeals of the revenue are dismissed

ITA 240/DEL/2018[2011-12]Status: DisposedITAT Delhi09 Dec 2020AY 2011-12

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 240/Del/2018 : Asstt. Year : 2011-12 Ita No. 241/Del/2018 : Asstt. Year : 2012-13 Ita No. 242/Del/2018 : Asstt. Year : 2014-15 Acit(E), Vs Delhi Bureau Of Text Books, Circle-1(1), 25/2, Institutional Area, Pankha New Delhi Road, D-Block, Janakpuri, New Delhi-110058 (Appellant) (Respondent) Pan No. Aaatd4122G Assessee By : Sh. Amit Kumar Gupta, Adv. Revenue By : Sh. Jagdish Singh, Sr. Dr Date Of Hearing: 24.11.2020 Date Of Pronouncement: 09.12.2020

For Appellant: Sh. Amit Kumar Gupta, AdvFor Respondent: Sh. Jagdish Singh, Sr. DR
Section 10Section 11Section 12ASection 2(15)

…67 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 408 (Ori), Institution of Chartered Accountants of India vs. Director General of Income Tax (Exemptions) (2012) 347 ITR 99 (Del), Commissioner of Income Tax vs. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP), General of Income Tax (Exemptions) (2014) 362 ITR 436 (Del), examined the question of interpretation placed on the word 'education' occurring in section 2(15) of the Ad, and reached the conclusion that merely because the assessee had generated profits out of the activity of publishing and selling of School text books, it cannot be said that…

Seth Anandram Jaipuria Education Society, Ghaziabad vs. DCIT (Exemption), Ghaziabad

In the result the appeal of the assessee with respect to ground

ITA 2615/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Sept 2017AY 2013-14

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishiseth Anandram Jaipuria Education Vs. Dcit (Exemption), Society, Exemption Circle, Sector-14C, Vasundhara, Ghaziabad Ghaziabad Pan:Aaaas0860P (Appellant) (Respondent)

For Appellant: Smt Paramita Tripathy, CIT DRFor Respondent: Sh. RS Singhvi, CA
Section 11Section 11(1)Section 12Section 143Section 2(15)

…olding coaching classes and that this amounted to business” and that therefore, „the question whether the Institute carried on business had not been examined with proper perspective.” 25. In Commissioner of Income Tax v. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP) the Madhya Pradesh High Court held as under: “17. From a perusal of the aforesaid decisions, it is lucid that for the entitlement for getting exemption for the assessment year, it is required to see the activities of the Assessee. That is the acid test. If the income/profit is applied for non-educational purposes, it is decided only at the e…

Delhi Bureau of Text Books vs. Director of Income Tax(E)

The appeals are allowed but, in the circumstances, with no orders as to costs

ITA/807/2015HC Delhi03 May 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 12ASection 2Section 260

…oaching classes and that this amounted to business” and that therefore, „the question whether the Institute carried on business had not been examined with proper perspective.” 25. In Commissioner of Income Tax v. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP) the Madhya Pradesh High Court held as under: “17. From a perusal of the aforesaid decisions, it is lucid that for the entitlement for getting exemption for the assessment year, it is required to see the activities of the Assessee. That is the acid test. If the income/profit is applied for non-educational purposes, it is decide…

Delhi Bureau of Text Books vs. Director of Income Tax(E)

The appeals are allowed but, in the circumstances, with no orders as to costs

ITA/812/2015HC Delhi03 May 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 12ASection 2Section 260

…oaching classes and that this amounted to business” and that therefore, „the question whether the Institute carried on business had not been examined with proper perspective.” 25. In Commissioner of Income Tax v. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP) the Madhya Pradesh High Court held as under: “17. From a perusal of the aforesaid decisions, it is lucid that for the entitlement for getting exemption for the assessment year, it is required to see the activities of the Assessee. That is the acid test. If the income/profit is applied for non-educational purposes, it is decide…

Delhi Bureau of Text Books vs. Director of Income Tax (E)

The appeals are allowed but, in the circumstances, with no orders as to costs

ITA/811/2015HC Delhi03 May 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 12ASection 2Section 260

…oaching classes and that this amounted to business” and that therefore, „the question whether the Institute carried on business had not been examined with proper perspective.” 25. In Commissioner of Income Tax v. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP) the Madhya Pradesh High Court held as under: “17. From a perusal of the aforesaid decisions, it is lucid that for the entitlement for getting exemption for the assessment year, it is required to see the activities of the Assessee. That is the acid test. If the income/profit is applied for non-educational purposes, it is decide…

Delhi Bureau of Text Books vs. Director of Income Tax (E)

The appeals are allowed but, in the circumstances, with no orders as to costs

ITA/810/2015HC Delhi03 May 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 12ASection 2Section 260

…oaching classes and that this amounted to business” and that therefore, „the question whether the Institute carried on business had not been examined with proper perspective.” 25. In Commissioner of Income Tax v. M.P. Rajya Pathya Pustak Nigam (2009) 226 CTR 497 (MP) the Madhya Pradesh High Court held as under: “17. From a perusal of the aforesaid decisions, it is lucid that for the entitlement for getting exemption for the assessment year, it is required to see the activities of the Assessee. That is the acid test. If the income/profit is applied for non-educational purposes, it is decide…