Council for the Indian School Certificate Examinations v. DGIT(E)

362 ITR 436High Court2014#3222 most cited

What is Council for the Indian School Certificate Examinations v. DGIT(E) authority for?

An organisation is considered an educational institution if its activities involve affiliating schools, prescribing syllabi, and conducting examinations, even if it does not directly conduct classes or teach students. Such activities are understood as educational and eligible for benefits under Sections 11 & 12 of the Income Tax Act.

37

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2025.

Also referred to as

Council for the Indian School Certificate Examinations v. DGIT(E) · section 2(15) · section 11 · section 12 · education · educational institution · affiliating schools · conducting examinations · syllabus

Also reported as

20 Taxmann.com 505206 Taxmann 466

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)advancement of general public utilitysection 10(23c)(vi)proviso to section 2(15)credit for tdssection 2(15)section 10(23c)interest under section 234asection 32regular assessmentsection 234b

Judgments citing Council for the Indian School Certificate Examinations v. DGIT(E)

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

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 5422 to 5429/Mum/2025 (Assessment Year: 2010-11 to 2017-18) GIA India The Income Tax Officer GIA India, 10th Floor, Trade Centre, (Exemptions) –II(1), Mumbai Bandra Kurla complex, Bandra (East), MTNL Tel. Ex. Building, Vs. Mumbai 400051 Cumballa Hill, Pedder Road, Mumbai 400026 PAN: AACCG1253E Appellant) : Respondent) : Shri. J.D. Mistry, Sr. Advocate & Shri. Assessee by Gunjan Kakkad Revenue by : Shri. Swapnil Choudhary Sr. AR Date of Hearing : 29.10.2025 Date of Pronouncement : 11.11…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 5422 to 5429/Mum/2025 (Assessment Year: 2010-11 to 2017-18) GIA India The Income Tax Officer GIA India, 10th Floor, Trade Centre, (Exemptions) –II(1), Mumbai Bandra Kurla complex, Bandra (East), MTNL Tel. Ex. Building, Vs. Mumbai 400051 Cumballa Hill, Pedder Road, Mumbai 400026 PAN: AACCG1253E Appellant) : Respondent) : Shri. J.D. Mistry, Sr. Advocate & Shri. Assessee by Gunjan Kakkad Revenue by : Shri. Swapnil Choudhary Sr. AR Date of Hearing : 29.10.2025 Date of Pronouncement : 11.11…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 5422 to 5429/Mum/2025 (Assessment Year: 2010-11 to 2017-18) GIA India The Income Tax Officer GIA India, 10th Floor, Trade Centre, (Exemptions) –II(1), Mumbai Bandra Kurla complex, Bandra (East), MTNL Tel. Ex. Building, Vs. Mumbai 400051 Cumballa Hill, Pedder Road, Mumbai 400026 PAN: AACCG1253E Appellant) : Respondent) : Shri. J.D. Mistry, Sr. Advocate & Shri. Assessee by Gunjan Kakkad Revenue by : Shri. Swapnil Choudhary Sr. AR Date of Hearing : 29.10.2025 Date of Pronouncement : 11.11…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 5422 to 5429/Mum/2025 (Assessment Year: 2010-11 to 2017-18) GIA India The Income Tax Officer GIA India, 10th Floor, Trade Centre, (Exemptions) –II(1), Mumbai Bandra Kurla complex, Bandra (East), MTNL Tel. Ex. Building, Vs. Mumbai 400051 Cumballa Hill, Pedder Road, Mumbai 400026 PAN: AACCG1253E Appellant) : Respondent) : Shri. J.D. Mistry, Sr. Advocate & Shri. Assessee by Gunjan Kakkad Revenue by : Shri. Swapnil Choudhary Sr. AR Date of Hearing : 29.10.2025 Date of Pronouncement : 11.11…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 5422 to 5429/Mum/2025 (Assessment Year: 2010-11 to 2017-18) GIA India The Income Tax Officer GIA India, 10th Floor, Trade Centre, (Exemptions) –II(1), Mumbai Bandra Kurla complex, Bandra (East), MTNL Tel. Ex. Building, Vs. Mumbai 400051 Cumballa Hill, Pedder Road, Mumbai 400026 PAN: AACCG1253E Appellant) : Respondent) : Shri. J.D. Mistry, Sr. Advocate & Shri. Assessee by Gunjan Kakkad Revenue by : Shri. Swapnil Choudhary Sr. AR Date of Hearing : 29.10.2025 Date of Pronouncement : 11.11…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 5422 to 5429/Mum/2025 (Assessment Year: 2010-11 to 2017-18) GIA India The Income Tax Officer GIA India, 10th Floor, Trade Centre, (Exemptions) –II(1), Mumbai Bandra Kurla complex, Bandra (East), MTNL Tel. Ex. Building, Vs. Mumbai 400051 Cumballa Hill, Pedder Road, Mumbai 400026 PAN: AACCG1253E Appellant) : Respondent) : Shri. J.D. Mistry, Sr. Advocate & Shri. Assessee by Gunjan Kakkad Revenue by : Shri. Swapnil Choudhary Sr. AR Date of Hearing : 29.10.2025 Date of Pronouncement : 11.11…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 5422 to 5429/Mum/2025 (Assessment Year: 2010-11 to 2017-18) GIA India The Income Tax Officer GIA India, 10th Floor, Trade Centre, (Exemptions) –II(1), Mumbai Bandra Kurla complex, Bandra (East), MTNL Tel. Ex. Building, Vs. Mumbai 400051 Cumballa Hill, Pedder Road, Mumbai 400026 PAN: AACCG1253E Appellant) : Respondent) : Shri. J.D. Mistry, Sr. Advocate & Shri. Assessee by Gunjan Kakkad Revenue by : Shri. Swapnil Choudhary Sr. AR Date of Hearing : 29.10.2025 Date of Pronouncement : 11.11…

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

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 5422 to 5429/Mum/2025 (Assessment Year: 2010-11 to 2017-18) GIA India The Income Tax Officer GIA India, 10th Floor, Trade Centre, (Exemptions) –II(1), Mumbai Bandra Kurla complex, Bandra (East), MTNL Tel. Ex. Building, Vs. Mumbai 400051 Cumballa Hill, Pedder Road, Mumbai 400026 PAN: AACCG1253E Appellant) : Respondent) : Shri. J.D. Mistry, Sr. Advocate & Shri. Assessee by Gunjan Kakkad Revenue by : Shri. Swapnil Choudhary Sr. AR Date of Hearing : 29.10.2025 Date of Pronouncement : 11.11…

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

…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 that they ceased to carry on the activity of education and by f…

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

…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 that they ceased to carry on the activity of education and by f…

Jt. Comm of Income Tax(OSD) (E) -2(1), Mumbai vs. Maharashtra State Road Transport Corporation, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1500/MUM/2022[2014-15]Status: DisposedITAT Mumbai20 Sept 2022AY 2014-15
Section 11Section 12ASection 2(15)

…shops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'ble Delhi High Court in the case of Council for the Indian School Certificate Examinations vs DGIT(E), 362 ITR 436 (Delhi) was considering the activities of an assessee who was neither conducting any classes and nor was directly engaged in teaching students, but was only affiliating schools, prescribing syllabus and conducting examinations. The 8 Maharashtra State Road Transport Corporation institution carrying out such activities was also understood by the H…

Jt. Comm of Income Tax(OSD) (E) -2(1), Mumbai vs. Maharashtra State Road Transport. Corporation, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1496/MUM/2022[2009-10]Status: DisposedITAT Mumbai20 Sept 2022AY 2009-10
Section 11Section 12ASection 2(15)

…shops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'ble Delhi High Court in the case of Council for the Indian School Certificate Examinations vs DGIT(E), 362 ITR 436 (Delhi) was considering the activities of an assessee who was neither conducting any classes and nor was directly engaged in teaching students, but was only affiliating schools, prescribing syllabus and conducting examinations. The 8 Maharashtra State Road Transport Corporation institution carrying out such activities was also understood by the H…

Indian Academy of Highway Engineers, Noida vs. CIT(E), Lucknow

ITA 645/DEL/2021[----]Status: DisposedITAT Delhi30 Jun 2022

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 645 /Del/2021 (Assessment Year : ……..)

Section 10

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘C’ : NEW DELHI) (Through Video Conferencing) BEFORE SH. G.S.PANNU, HON’BLE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No. 645 /Del/2021 (Assessment Year : ……..) Indian Academy of Highway Vs. CIT(Exemptions) Engineers Lukhnow, A-5, Industrial Area, Sec-62, Noida PAN : AABAI2196K (APPELLANT) (RESPONDENT) Assessee by Sh. Akhilesh Kumar, Adv. Sh. Vipin Garg, Adv. Revenue by Ms. Deepshikha Sharma, CIT(DR) Date of hearing: 10.06.2022 Date of Pronouncement: 30.06.2022 ORDER PER ANUBHAV SHARMA, JM: The appeal has been preferred by the assessee…

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

…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 that they ceased to carry on the activity of education and by f…

The Marg Foundation, Mumbai vs. ITO (E) 2(4), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 889/MUM/2017[2012-13]Status: DisposedITAT Mumbai30 Mar 2021AY 2012-13
Section 11Section 12ASection 143(3)Section 2(15)

…ferred to above have laid down the criteria under what circumstances an Assessee can claim exemption being involved in educational purposes and how the income is spent." 26. In Council for the Indian School Certificate Examinations v. DGIT (Exemptions) [2014] 362 ITR 436/[2012] 20 taxmann.com 505/206 Taxman 466 (Delhi) the Court held the Council for the Indian School Certificate Examinations to be an educational institution and quashed the order which denied it exemption under Section 10 (23c) (vi) of the Act. It was reiterated as under: "It is, therefore, clear that courts have laid emphasis on the activity unde…

DCIT (E) 2(1), Mumbai vs. Mumbai Railway Vikas Corpn Ltd, Mumbai

In the result, all the Four appeals filed by the revenue and four cross objections filed by the assessee are dismissed

ITA 2877/MUM/2019[2009-10]Status: DisposedITAT Mumbai29 Jan 2021AY 2009-10

Bench: Shri Rajesh Kumar & Shri Pavan Kumar Gadale

For Appellant: Shri T. Kipgan, CIT-DR
Section 11Section 143(3)Section 2Section 2(15)Section 25Section 617

…shops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'ble Delhi High Court in the case of Council for the Indian School Certificate Examinations vs DGIT(E), 362 ITR 436 (Delhi) was considering the activities of an assessee who was neither conducting any classes and nor was directly engaged in teaching students, but was only affiliating schools, prescribing syllabus and conducting examinations. The institution carrying out such activities was also understood by the Hon'ble Court to be an educational institution.…

DCIT (E) 2(1), Mumbai vs. Mumbai Railway Vikas Corpn Ltd, Mumbai

ITA 2883/MUM/2019[2015-16]Status: DisposedITAT Mumbai05 Jan 2021AY 2015-16
Section 11Section 143(3)Section 2(15)Section 2(25)

…shops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'ble Delhi High Court in the case of Council for the Indian School Certificate Examinations vs DGIT(E), 362 ITR 436 (Delhi) was considering the activities of an assessee who was neither conducting any classes and nor was directly engaged in teaching students, but was only affiliating schools, prescribing syllabus and conducting examinations. The institution carrying out CO No 45/Mum/20 ITA No. 2883/Mum/19 Assessment year: 2015-16 Page 33 of 38 such activities…

DCIT (E) 2(1), Mumbai vs. Mumbai Railway Vikas Corpn Ltd, Mumbai

ITA 2881/MUM/2019[2013-14]Status: DisposedITAT Mumbai05 Jan 2021AY 2013-14
Section 11Section 143(3)Section 2(15)Section 2(25)

…shops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'ble Delhi High Court in the case of Council for the Indian School Certificate Examinations vs DGIT(E), 362 ITR 436 (Delhi) was considering the activities of an assessee who was neither conducting any classes and nor was directly engaged in teaching students, but was only affiliating schools, prescribing syllabus and conducting examinations. The institution carrying out CO No 43/Mum/20 ITA No. 2881/Mum/19 Assessment year: 2013-14 Page 33 of 38 such activities…

DCIT (E) 2(1), Mumbai vs. Mumbai Railway Vikas Corpn Ltd, Mumbai

ITA 2880/MUM/2019[2012-13]Status: DisposedITAT Mumbai05 Jan 2021AY 2012-13
Section 11Section 143(3)Section 2(15)Section 2(25)Section 617

…shops, etc. Such like activities were also held to be in the nature of 'education' eligible for the benefit of Sections 11 & 12 of the Act. In fact, the Hon'ble Delhi High Court in the case of Council for the Indian School Certificate Examinations vs DGIT(E), 362 ITR 436 (Delhi) was considering the activities of an assessee who was neither conducting any classes and nor was directly engaged in teaching students, but was only affiliating schools, prescribing syllabus and conducting examinations. The institution carrying out such activities was also understood by the Hon'ble Court to be an educational institution.…

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)

…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 they ceased to carry on the activity of education and by fo…