Bihar Institute of Mining & Mine Surveying v. CIT

HARMONY EDUCATIONAL FOUNDATION,PUNE vs. CIT(E), PUNE

In the result, appeal of the Assessee is dismissed

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1993/Pun/2024 निर्धारण वषा / Assessment Year: 2025-26 Harmony Educational V The Commissioner Of Foundation, S Income Tax(Exemption), 1430, Satav Vasti, Wagholi Pune. Lohegaon Road, Wagholi, Pune – 411047. Maharashtra. Pan: Aafch1576E Appellant/ Assessee Respondent / Revenue Assessee By Ca Abhay A Avchat & Mrs.Ruchi Agarwal(Director) – Ar Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 28/10/2025 Date Of Pronouncement 31/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption) Dated 24.07.2024 Rejecting Registration Under Section 12A(1)(Ac) Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal:

…rror of not granting registration to the Assessee Company.” 21.1 The Hon‟ble Supreme Court has held that „Education means Structured Education‟. The Hon‟ble Gujarat High Court in the case 16 ITA No.1993/PUN/2024 [A] CIT Vs. Sorabji Nusserwanji Parekh (1993) 201 ITR 939, held as under : „There should be activity of normal schooling or actual imparting of education by the institution.‟ 22. For the purpose of Section 2(15) of the Income Tax Act, Education means Structured Education. In the case of the Assessee, Assessee is running a school without having approval of Competent Authority which is an act against pub…