CIT v. Doon Foundation

154 ITR 208High Court1985#4895 most cited

What is CIT v. Doon Foundation authority for?

An educational institution is eligible for exemption under Section 10(22) if it exists solely for educational purposes and not for profit, regardless of affiliation with a university or board.

24

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. Doon Foundation · Section 10(22) · educational institution exemption · not for profit · affiliation · sole purpose educational

Also reported as

22 Taxmann 9

Sections most often in play

Section 11Section 2(15)Section 11(4)Section 234ASection 234BSection 32Section 10(23C)Section 12

Issues it is cited on

section 10(22)section 11(4)section 35acsection 115bbcsection 35asection 2(45)anonymous donationadvancement of general public utilitysection 60section 11(4a)rectification under section 154corpus fund

Judgments citing CIT v. Doon Foundation

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5429/MUM/2025[2017-18]Status: DisposedITAT Mumbai11 Nov 2025AY 2017-18

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…has further been observed that the word also connotes the process of training and development of knowledge, skill, mind and character of students by normal schooling. 10. We may refer to the judgment of the Calcutta High Court in CIT v. Doon Foundation [1985] 154 ITR 208/22 Taxman 9. Interpreting the provisions of Section 10(22) of the Act, the High Court observed as under:- "We are also unable to accept the contention of Mr. Maitra that an educational institution to be eligible for exemption under Section 10(22) should be affiliated to any university or any board. Section 10(22) does not impose such a condition…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5428/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Nov 2025AY 2016-17

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…has further been observed that the word also connotes the process of training and development of knowledge, skill, mind and character of students by normal schooling. 10. We may refer to the judgment of the Calcutta High Court in CIT v. Doon Foundation [1985] 154 ITR 208/22 Taxman 9. Interpreting the provisions of Section 10(22) of the Act, the High Court observed as under:- "We are also unable to accept the contention of Mr. Maitra that an educational institution to be eligible for exemption under Section 10(22) should be affiliated to any university or any board. Section 10(22) does not impose such a condition…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5427/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Nov 2025AY 2015-16

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…has further been observed that the word also connotes the process of training and development of knowledge, skill, mind and character of students by normal schooling. 10. We may refer to the judgment of the Calcutta High Court in CIT v. Doon Foundation [1985] 154 ITR 208/22 Taxman 9. Interpreting the provisions of Section 10(22) of the Act, the High Court observed as under:- "We are also unable to accept the contention of Mr. Maitra that an educational institution to be eligible for exemption under Section 10(22) should be affiliated to any university or any board. Section 10(22) does not impose such a condition…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5426/MUM/2025[2014-15]Status: DisposedITAT Mumbai11 Nov 2025AY 2014-15

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…has further been observed that the word also connotes the process of training and development of knowledge, skill, mind and character of students by normal schooling. 10. We may refer to the judgment of the Calcutta High Court in CIT v. Doon Foundation [1985] 154 ITR 208/22 Taxman 9. Interpreting the provisions of Section 10(22) of the Act, the High Court observed as under:- "We are also unable to accept the contention of Mr. Maitra that an educational institution to be eligible for exemption under Section 10(22) should be affiliated to any university or any board. Section 10(22) does not impose such a condition…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5425/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Nov 2025AY 2013-14

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…has further been observed that the word also connotes the process of training and development of knowledge, skill, mind and character of students by normal schooling. 10. We may refer to the judgment of the Calcutta High Court in CIT v. Doon Foundation [1985] 154 ITR 208/22 Taxman 9. Interpreting the provisions of Section 10(22) of the Act, the High Court observed as under:- "We are also unable to accept the contention of Mr. Maitra that an educational institution to be eligible for exemption under Section 10(22) should be affiliated to any university or any board. Section 10(22) does not impose such a condition…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5424/MUM/2025[2012-13]Status: DisposedITAT Mumbai11 Nov 2025AY 2012-13

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…has further been observed that the word also connotes the process of training and development of knowledge, skill, mind and character of students by normal schooling. 10. We may refer to the judgment of the Calcutta High Court in CIT v. Doon Foundation [1985] 154 ITR 208/22 Taxman 9. Interpreting the provisions of Section 10(22) of the Act, the High Court observed as under:- "We are also unable to accept the contention of Mr. Maitra that an educational institution to be eligible for exemption under Section 10(22) should be affiliated to any university or any board. Section 10(22) does not impose such a condition…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5423/MUM/2025[2011-12]Status: DisposedITAT Mumbai11 Nov 2025AY 2011-12

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…has further been observed that the word also connotes the process of training and development of knowledge, skill, mind and character of students by normal schooling. 10. We may refer to the judgment of the Calcutta High Court in CIT v. Doon Foundation [1985] 154 ITR 208/22 Taxman 9. Interpreting the provisions of Section 10(22) of the Act, the High Court observed as under:- "We are also unable to accept the contention of Mr. Maitra that an educational institution to be eligible for exemption under Section 10(22) should be affiliated to any university or any board. Section 10(22) does not impose such a condition…

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5422/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Nov 2025AY 2010-11

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

…has further been observed that the word also connotes the process of training and development of knowledge, skill, mind and character of students by normal schooling. 10. We may refer to the judgment of the Calcutta High Court in CIT v. Doon Foundation [1985] 154 ITR 208/22 Taxman 9. Interpreting the provisions of Section 10(22) of the Act, the High Court observed as under:- "We are also unable to accept the contention of Mr. Maitra that an educational institution to be eligible for exemption under Section 10(22) should be affiliated to any university or any board. Section 10(22) does not impose such a condition…

The Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 66/BANG/2018[2014-15]Status: DisposedITAT Bangalore29 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…lar body running an educational institution solely for educational purposes and not for the purpose of profit could be regarded as 'other educational institution' coming within s. 10(22) of the Act [See CIT vs. Doon Foundation (1986) 53 CTR (Cal) 440 : (1985) 154 ITR 208 (Cal) and Agarwal Shiksha Samiti Trust vs. CIT (1987) 66 CTR (Raj) 95 : (1987) 168 ITR 751 (Raj)]. It will be rather unreal and hyper-technical to hold that the assessee-society is only a financing body and will not come within the scope of 'other educational institution' as specified in s. 10(22) of the Act. The object of the society is to estab…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 65/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…lar body running an educational institution solely for educational purposes and not for the purpose of profit could be regarded as 'other educational institution' coming within s. 10(22) of the Act [See CIT vs. Doon Foundation (1986) 53 CTR (Cal) 440 : (1985) 154 ITR 208 (Cal) and Agarwal Shiksha Samiti Trust vs. CIT (1987) 66 CTR (Raj) 95 : (1987) 168 ITR 751 (Raj)]. It will be rather unreal and hyper-technical to hold that the assessee-society is only a financing body and will not come within the scope of 'other educational institution' as specified in s. 10(22) of the Act. The object of the society is to estab…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 64/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Aug 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…lar body running an educational institution solely for educational purposes and not for the purpose of profit could be regarded as 'other educational institution' coming within s. 10(22) of the Act [See CIT vs. Doon Foundation (1986) 53 CTR (Cal) 440 : (1985) 154 ITR 208 (Cal) and Agarwal Shiksha Samiti Trust vs. CIT (1987) 66 CTR (Raj) 95 : (1987) 168 ITR 751 (Raj)]. It will be rather unreal and hyper-technical to hold that the assessee-society is only a financing body and will not come within the scope of 'other educational institution' as specified in s. 10(22) of the Act. The object of the society is to estab…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. Sri V C Charantimath, Bagalkot

In the result, the assessee’s appeals in ITA Nos

ITA 236/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…lar body running an educational institution solely for educational purposes and not for the purpose of profit could be regarded as 'other educational institution' coming within s. 10(22) of the Act [See CIT vs. Doon Foundation (1986) 53 CTR (Cal) 440 : (1985) 154 ITR 208 (Cal) and Agarwal Shiksha Samiti Trust vs. CIT (1987) 66 CTR (Raj) 95 : (1987) 168 ITR 751 (Raj)]. It will be rather unreal and hyper-technical to hold that the assessee-society is only a financing body and will not come within the scope of 'other educational institution' as specified in s. 10(22) of the Act. The object of the society is to estab…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. Sri.V.C.Charantimath, Bagalkot

In the result, the assessee’s appeals in ITA Nos

ITA 235/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Aug 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…lar body running an educational institution solely for educational purposes and not for the purpose of profit could be regarded as 'other educational institution' coming within s. 10(22) of the Act [See CIT vs. Doon Foundation (1986) 53 CTR (Cal) 440 : (1985) 154 ITR 208 (Cal) and Agarwal Shiksha Samiti Trust vs. CIT (1987) 66 CTR (Raj) 95 : (1987) 168 ITR 751 (Raj)]. It will be rather unreal and hyper-technical to hold that the assessee-society is only a financing body and will not come within the scope of 'other educational institution' as specified in s. 10(22) of the Act. The object of the society is to estab…

Assistant Commissioner of Income-Tax, Central Circle-2(2), Bengaluru vs. M/S. Sri. Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 234/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…lar body running an educational institution solely for educational purposes and not for the purpose of profit could be regarded as 'other educational institution' coming within s. 10(22) of the Act [See CIT vs. Doon Foundation (1986) 53 CTR (Cal) 440 : (1985) 154 ITR 208 (Cal) and Agarwal Shiksha Samiti Trust vs. CIT (1987) 66 CTR (Raj) 95 : (1987) 168 ITR 751 (Raj)]. It will be rather unreal and hyper-technical to hold that the assessee-society is only a financing body and will not come within the scope of 'other educational institution' as specified in s. 10(22) of the Act. The object of the society is to estab…

Sri Basaveshwar Veerashaiva Vidyavardhak Sagha, Bagalkot vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, the assessee’s appeals in ITA Nos

ITA 2777/BANG/2017[2014-15]Status: DisposedITAT Bangalore29 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…lar body running an educational institution solely for educational purposes and not for the purpose of profit could be regarded as 'other educational institution' coming within s. 10(22) of the Act [See CIT vs. Doon Foundation (1986) 53 CTR (Cal) 440 : (1985) 154 ITR 208 (Cal) and Agarwal Shiksha Samiti Trust vs. CIT (1987) 66 CTR (Raj) 95 : (1987) 168 ITR 751 (Raj)]. It will be rather unreal and hyper-technical to hold that the assessee-society is only a financing body and will not come within the scope of 'other educational institution' as specified in s. 10(22) of the Act. The object of the society is to estab…

Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkot vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, the assessee’s appeals in ITA Nos

ITA 2776/BANG/2017[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…lar body running an educational institution solely for educational purposes and not for the purpose of profit could be regarded as 'other educational institution' coming within s. 10(22) of the Act [See CIT vs. Doon Foundation (1986) 53 CTR (Cal) 440 : (1985) 154 ITR 208 (Cal) and Agarwal Shiksha Samiti Trust vs. CIT (1987) 66 CTR (Raj) 95 : (1987) 168 ITR 751 (Raj)]. It will be rather unreal and hyper-technical to hold that the assessee-society is only a financing body and will not come within the scope of 'other educational institution' as specified in s. 10(22) of the Act. The object of the society is to estab…

Sri Basaveshwar Veershaiva Vidyavardhak Sangha, Bagalkot vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, the assessee’s appeals in ITA Nos

ITA 2775/BANG/2017[2012-13]Status: DisposedITAT Bangalore29 Aug 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…lar body running an educational institution solely for educational purposes and not for the purpose of profit could be regarded as 'other educational institution' coming within s. 10(22) of the Act [See CIT vs. Doon Foundation (1986) 53 CTR (Cal) 440 : (1985) 154 ITR 208 (Cal) and Agarwal Shiksha Samiti Trust vs. CIT (1987) 66 CTR (Raj) 95 : (1987) 168 ITR 751 (Raj)]. It will be rather unreal and hyper-technical to hold that the assessee-society is only a financing body and will not come within the scope of 'other educational institution' as specified in s. 10(22) of the Act. The object of the society is to estab…

Abhinayavani Nritya Niketan, Hyderabad vs. Commissioner of Income Tax, (Exemptions), Hyderabad

In the result, appeal filed by the assessee in ITA NO

ITA 995/HYD/2019[0]Status: DisposedITAT Hyderabad28 Nov 2019

Bench: Shri A. Mohan Alankamony & Shri V. Durga Rao

For Respondent: Shri Y.V.S.T.Sai, CIT, D.R
Section 12ASection 80G

…nd circumstances of the case and also by considering the above decision of the ITAT, Chennai Bench, we find that the assessee is entitled for registration u/sec, 12A of the Act. 9. The Hon'ble Calcutta High Court in the case of CIT Vs. Doon Foundation [(1985) 154 ITR 208] wherein it was held that "educational institutions need not be affiliated to Universities or Boards and what is to be seen is that the object clause of the trust is for educational purposes and it has carried out a full-fledged teaching of the relevant course". 10. The Hon'ble Karnataka High Court in the case of CIT Vs. Academy of General Educat…

Abhinayavani Nritya Niketan, Hyderabad vs. Commissioner of Income Tax, (Exemptions), Hyderabad

In the result, appeal filed by the assessee in ITA NO

ITA 994/HYD/2019[0]Status: DisposedITAT Hyderabad28 Nov 2019

Bench: Shri A. Mohan Alankamony & Shri V. Durga Rao

For Respondent: Shri Y.V.S.T.Sai, CIT, D.R
Section 12ASection 80G

…nd circumstances of the case and also by considering the above decision of the ITAT, Chennai Bench, we find that the assessee is entitled for registration u/sec, 12A of the Act. 9. The Hon'ble Calcutta High Court in the case of CIT Vs. Doon Foundation [(1985) 154 ITR 208] wherein it was held that "educational institutions need not be affiliated to Universities or Boards and what is to be seen is that the object clause of the trust is for educational purposes and it has carried out a full-fledged teaching of the relevant course". 10. The Hon'ble Karnataka High Court in the case of CIT Vs. Academy of General Educat…

DCIT (International Taxation), Gurgaon vs. M/S. Msv International Inc., Gurgaon

In the result appeal of the revenue is dismissed

ITA 2187/DEL/2016[2005-06]Status: DisposedITAT Delhi12 Feb 2019AY 2005-06

Bench: Smt Diva Singh & Shri R.K. Panda

Section 143(3)Section 147Section 44D

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘E’ NEW DELHI BEFORE SMT DIVA SINGH, JUDICIAL MEMBER AND SHRI R.K. PANDA, ACCOUNTANT MEMBER ITA No.-2187/Del/2016 (Assessment Year: 2005-06) DCIT (International Taxation) vs MSV International Inc. Circle-Gurgaon, D-7, South City-1 307, HSIDC building, Udyog Gurgaon-122002 Vihar-V PAN AADCM1304M Gurgaon Revenue by Ms. Rinku Singh, Sr. (DR) Assessee by Shri Ved Jain, Advocate, Shri Ashish Goel, CA, Ms. Surbhi Goel, CA, Shri Kislaya Parashar, Advocate Date of Hearing 03.01.2019 Date of Pronouncement 12.02.2019 ORDER The present appeal has been filed by the asse…