What is Pinegrove International Charitable Trust v. UOI authority for?

An educational institution qualifies for exemption under Section 10(23C)(vi) if its predominant object is solely education and not to earn profit. The mere generation of a surplus or profit from imparting education does not, by itself, disentitle it from the exemption, provided the income is applied for its educational objects.

Which sections of the Income Tax Act does Pinegrove International Charitable Trust v. UOI come up under?

It is most often cited in judgments turning on Section 10(23C)(vi), Section 143(1), Section 143(3), Section 250, Section 10(23C)(iiiad), Section 142(1).

Pinegrove International Charitable Trust v. UOI (327 ITR 73)

Q: How many judgments cite Pinegrove International Charitable Trust v. UOI?

56 judgments on BharatTax cite Pinegrove International Charitable Trust v. UOI (327 ITR 73), spanning 2015 to 2026.

S.D EDUCATION SOCIETY,KARNAL vs. ACIT CIRCLE, KARNAL

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 5224/DEL/2025[2011-12]Status: DisposedITAT Delhi07 Jan 2026AY 2011-12

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Girish Aneja, CAFor Respondent: Ms Ankush Kalra, Sr. DR

Section 10Section 143(1)Section 143(2)Section 143(3)Section 250

…reme Court vide judgment dated 10.05.2016 passed in a bunch of appeals including CA No.95942 of 2013 has adjudicated the issue. Supreme Court has considered judgment of this Court passed in “Pinegrove International Charitable Trust Vs. Union of India”, (2010) 327 ITR 73 (P&H). The matter needs to be reconsidered by competent authority in the light of different judgments passed by Supreme Court including afore-cited judgment. 5. In the wake of statement of both sides, the matters are remanded to respondent-jurisdictional competent authority to pass fresh order after granting opportunity of hearing to petitioners.…

S.D EDUCATION SOCIETY,KARNAL vs. ACIT CIRCLE KARNAL, KARNAL

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 5223/DEL/2025[2010-11]Status: DisposedITAT Delhi07 Jan 2026AY 2010-11

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Girish Aneja, CAFor Respondent: Ms Ankush Kalra, Sr. DR

Section 10Section 143(1)Section 143(2)Section 143(3)Section 250

…reme Court vide judgment dated 10.05.2016 passed in a bunch of appeals including CA No.95942 of 2013 has adjudicated the issue. Supreme Court has considered judgment of this Court passed in “Pinegrove International Charitable Trust Vs. Union of India”, (2010) 327 ITR 73 (P&H). The matter needs to be reconsidered by competent authority in the light of different judgments passed by Supreme Court including afore-cited judgment. 5. In the wake of statement of both sides, the matters are remanded to respondent-jurisdictional competent authority to pass fresh order after granting opportunity of hearing to petitioners.…

CT EDUCATIONAL SOCIETY,JALANDHAR vs. DCIT, CHANDIGARH

In the result, the appeal filed by the Assessee is Partly Allowed for\nStatistical Purposes as per the directions above

ITA 396/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh10 Dec 2025AY 2016-17

For Appellant: Shri Ashray Sarna, CA(Virtual Mode)For Respondent: Shri Manav Bansal, CIT, DR

Section 11Section 12ASection 13(1)(c)Section 13(2)Section 143(2)Section 143(3)Section 2(15)Section 250

…lts in making a profit,\nno inference arises that it has become an activity for profit.\nReliance is further placed on the decision of Hon'ble Punjab & Haryana High\nCourt in the case of Pinegrove International Charitable Trust V/s Union of India\n&Ors (2010) 327 ITR 73 (P&H) : (2010) 230 CTR (P&H) 477 : (2010) 188 ΤΑΧΜΑΝ 402\n(P&H): (2010) 37 DTR (P&H) 105 in which it was held as under:\nExemption under s.10(23C)(vi)—Educational institution, university, etc.—Profit\nmotive-Assessee society's application of income is undisputedly more than 100\nper cent for the attainment and achievement of its objects in the las…

MAHARISHI DAYANAND EDUCATION SOCIETY ,PUNJAB vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS )CHANDIGARH , CHANDIGARH

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 343/ASR/2024[2019-2020]Status: DisposedITAT Amritsar09 Jan 2025AY 2019-2020

Bench: Sh. Vikram Singh Yadav & Sh. Udayan Dasgupta

For Appellant: Sh. Sudhir Sehgal & Sh. A.K. Periwal, C.A

Section 10

…al Punjab & Haryana High Court in the case of Sanatan Dharam Shiksha Samiti, reported in 19 Taxmann.com 87 and also placed relaince on the judgment of Hon’ble Punjab & Haryana High Court in the case of Pinegrove International Charitable Trust, reported in 327 ITR 73, wherein it has been held as under: 7 I.T.A. No.343/Asr/2024 Maharishi Dayanand Education Society v. CIT “Section 10(23C)(vi) of the Income Tax Act, 1961 - Educational institutions - Assessment years 2000-01 to 2007-08 - Whether to decide entitlement of an institution for exemption under section 10(23C)(vi), test of predominant object of its ac…

COMMISSIONER OF INCOME TAX, vs. SIKHYA\"O\"ANUSANDHAN

ITA/17/2015HC Orissa03 Jan 2023

Bench: The Itat Against The Respondent-Assessee For The Assessment Years (Ays) 2007-08 Till 2012-13.

Section 11Section 11(1)(a)Section 12

…enence Educational Society v. CIT (2010) 197 Taxman 504 (Del.) and the judgment of the Punjab and Haryana High Court Page 3 of 4 in Pinegrove International Charitable Trust v. Union of India (2010) 327 ITR 73 (P & H). Reference was again made to the decision of the Supreme Court of India in Aditanar Educational Institution v. Additional CIT (1997) 224 ITR 310 (SC). 5. In the impugned order, the ITAT has concurred with the CIT(A) and that the conclusion was based on the various decisions of the Supreme Court of India. 6. At this stage, Mr. Radh…

COMNR.OF INCOME TAX vs. SIKHYA O ANUSANDHAN

ITA/34/2013HC Orissa03 Jan 2023

Bench: The Itat Against The Respondent-Assessee For The Assessment Years (Ays) 2007-08 Till 2012-13.

Section 11Section 11(1)(a)Section 12

…enence Educational Society v. CIT (2010) 197 Taxman 504 (Del.) and the judgment of the Punjab and Haryana High Court Page 3 of 4 in Pinegrove International Charitable Trust v. Union of India (2010) 327 ITR 73 (P & H). Reference was again made to the decision of the Supreme Court of India in Aditanar Educational Institution v. Additional CIT (1997) 224 ITR 310 (SC). 5. In the impugned order, the ITAT has concurred with the CIT(A) and that the conclusion was based on the various decisions of the Supreme Court of India. 6. At this stage, Mr. Radh…

M/S NEW NOBLE EDUCATIONAL SOCIETY vs. THE CHIEF COMMISSIONER OF INCOME TAX 1

The appeals are hereby dismissed, without order on costs

C.A. No.-003795-003795 - 2014Supreme Court19 Oct 2022

Bench: HON'BLE THE CHIEF JUSTICE

Section 10

…tional institutions, which are registered as a society, would continue to retain their character as such and would be eligible to apply for exemption under section 10(23C)(vi) of the Act. (Pine-grove International Charitable Trust v. Union of India, [2010] 327 ITR 73 (P&H)). The distinction sought to be made between the society, and the educational institution run by it, does not, therefore, merit acceptance. 8. In order to be eligible for exemption, under section 10(23C)(vi) of the Act, it is necessary that there must exist an educational institution. Secondly, such institution must exist solely for edu…

THE REDIANT WAY SCHOOL,RAIPUR (CG) vs. THE THE CHIF COMMISIONER OF INCOME TAX, RAIPUR (CG)

In the result, the appeal of assessee is allowed

ITA 15/BIL/2017[2013-14]Status: DisposedITAT Raipur21 Sept 2022AY 2013-14

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri P.K.Mishra, CIT-DR

Section 10Section 253

…erprets this aspect as under:- a. Queen's Educational Society v. CIT 55 taxmann.com 255 [2015] (SC) The Hon'bie Apex Court has concurred and approved the Punjab & Haryana High Court judgment in Pinegrone International Charitable Trust v. Union of India [2010] 327 ITR 73/188 Taxman 402 where in it was held as under: "....The fact that the Petitioner has a surplus of income over expenditure for the three years in question, cannot by any stretch of logical reasoning lead to the conclusion that the Petitioner does not exist solely for educational purposes or, as that Chief Commissioner held that the Petitioner exists…

INCOME TAX OFFICER (EXEMPTIONS), WARD, JAIPUR, JAIPUR vs. RAJASTHAN CRICKET ASSOCIATION, JAIPUR

In the result, appeal of the Department is dismissed

ITA 68/JPR/2022[2013-14]Status: DisposedITAT Jaipur21 Jun 2022AY 2013-14

Bench: The Hon’Ble Tribunal In The Interest Of Justice.

For Appellant: Shri Shyam Lal Agarwal, CAFor Respondent: Ms Manisha Chandra, CIT fu/kZkfjrh dh vksj ls@

Section 11Section 12ASection 143(3)Section 147Section 148Section 2(15)

…is to make profit as opposed to educating persons.' 16. The Hon'ble Supreme Court in above decision also approved the decision of Hon'ble Punjab and Haryana High Court in case of Pinegrove International Charitable Trust v. Union of India [2010] 188 Taxman 402/327 ITR 73. In that case, Chief CIT, Chandigarh withdrew the exemption under section 10(23C)(vi) stating that the profits are substantial and arising year after year and not incidental as held in case of Aditanar Educational Institution and the assessee should reduce the fees and apply a fresh. In that background, the Hon'ble Punjab and Haryana High Court he…

INCOME TAX OFFICER (EXEMPTION),WARD, JAIPUR, JAIPUR vs. RAJASTHAN CRICKET ASSOCIATION, JAIPUR

In the result, appeal of the Department is dismissed

ITA 67/JPR/2022[2012-13]Status: DisposedITAT Jaipur21 Jun 2022AY 2012-13

Bench: The Hon’Ble Tribunal In The Interest Of Justice.

For Appellant: Shri Shyam Lal Agarwal, CAFor Respondent: Ms Manisha Chandra, CIT fu/kZkfjrh dh vksj ls@

Section 11Section 12ASection 143(3)Section 147Section 148Section 2(15)

…is to make profit as opposed to educating persons.' 16. The Hon'ble Supreme Court in above decision also approved the decision of Hon'ble Punjab and Haryana High Court in case of Pinegrove International Charitable Trust v. Union of India [2010] 188 Taxman 402/327 ITR 73. In that case, Chief CIT, Chandigarh withdrew the exemption under section 10(23C)(vi) stating that the profits are substantial and arising year after year and not incidental as held in case of Aditanar Educational Institution and the assessee should reduce the fees and apply a fresh. In that background, the Hon'ble Punjab and Haryana High Court he…

INCOME TAX OFFICER, JAIPUR vs. RAJASTHAN CRICKET ASSOCIATION, JAIPUR

In the result, appeal of the Department is dismissed

ITA 66/JPR/2022[2005]Status: DisposedITAT Jaipur21 Jun 2022

Bench: The Hon’Ble Tribunal In The Interest Of Justice.

For Appellant: Shri Shyam Lal Agarwal, CAFor Respondent: Ms Manisha Chandra, CIT fu/kZkfjrh dh vksj ls@

Section 11Section 12ASection 143(3)Section 147Section 148Section 2(15)

…is to make profit as opposed to educating persons.' 16. The Hon'ble Supreme Court in above decision also approved the decision of Hon'ble Punjab and Haryana High Court in case of Pinegrove International Charitable Trust v. Union of India [2010] 188 Taxman 402/327 ITR 73. In that case, Chief CIT, Chandigarh withdrew the exemption under section 10(23C)(vi) stating that the profits are substantial and arising year after year and not incidental as held in case of Aditanar Educational Institution and the assessee should reduce the fees and apply a fresh. In that background, the Hon'ble Punjab and Haryana High Court he…

SOUTHERN INDIA BANKS' STAFF TRAINING COLLEGE,BENGALURU vs. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), BENGALURU

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 267/BANG/2021[2019-20]Status: DisposedITAT Bangalore18 Mar 2022AY 2019-20

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year :2019-20 M/S. Southern India Banks’ Staff Vs. The Commissioner Of Income Tax Training College, (Exemptions), No.9, Shankar Math Road, Bengaluru. Shankarapuram, Basavanagudi, Bengaluru–560 004. Pan : Aaats 5632 E Appellant Respondent Assessee By : Smt. Prathibha R, Advocate Revenue By : Shri. Roumuan Paite, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 14.03.2022 Date Of Pronouncement : 16.03.2022 O R D E R

For Appellant: Smt. Prathibha R, AdvocateFor Respondent: Shri. Roumuan Paite, CIT(DR)(ITAT), Bengaluru

Section 10

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI B. R. BASKARAN, ACCOUNTANT MEMBER Assessment Year :2019-20 M/s. Southern India Banks’ Staff Vs. The Commissioner of Income Tax Training College, (Exemptions), No.9, Shankar Math Road, Bengaluru. Shankarapuram, Basavanagudi, Bengaluru–560 004. PAN : AAATS 5632 E APPELLANT RESPONDENT Assessee by : Smt. Prathibha R, Advocate Revenue by : Shri. Roumuan Paite, CIT(DR)(ITAT), Bengaluru. Date of hearing : 14.03.2022 Date of Pronouncement : 16.03.2022 O R D E R Per N. V. Vasudevan, Vice President : This is an…

GURU TEG BAHADUR EDUATIONAL TRUST,JALANDHAR vs. COMMISSIONER OF INCOME TAX (EXEMPTION), CHANDIGARH

ITA 301/ASR/2018[2018-19]Status: DisposedITAT Amritsar16 Aug 2021AY 2018-19

Bench: Sh. Laliet Kumar & Dr. M. L. Meenai.T.A. No. 301/Asr/2018 Assessment Year: 2018-19

Section 10Section 12Section 12A

…nd he relied in the case of CIT(E) vs. Sh. Mahavir Jain Society ITA No.231 of 2016 order dated 11th September, 2017 ( P & H ) and others as under : Sr. No Description Page No. 1. Pinegrove International Charitable Trust & Ors. Vs. Union of India & Ors. (2010) 327 ITR 73 (P&H) 1-24 2. 25-37 American Hotel & Lodging Association Educational Institute vs. Central Board of Direct Taxes & Ors. (2008) 301 ITR 86 (SC) 3. CIT vs. Vijay Vargiya Vani Charitable Trust (2014) 369 ITR 0360 (Raj) 38-41 4. Sree Anjaneya Medical Trust vs. CIT (2016) 382 ITR 0399 (Ker) 42-47 5. CIT vs. Surya Educational & Charitable Trust (2013)…

M/S BABA BANDA BAHADUR MEMORIAL AND EDUCATIONAL SOCIETY,FARIDKOT vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), CHANDIGARH

ITA 66/ASR/2017[2015-16]Status: DisposedITAT Amritsar16 Aug 2021AY 2015-16

Bench: Sh. Laliet Kumar & Dr. M. L. Meenai.T.A. No. 66/Asr/2017 Assessment Year:2015-16

Section 10Section 12ASection 2(15)

…twenty-five lakh rupees] or less in the previous year;' 9. These aspects have not been taken into consideration by the Tribunal which has placed heavy reliance upon the judgment of this Court in Pinegrove International Charitable Trust v. Union of India[2010] 327 ITR 73/188 Taxman 402 (Punj. & Har.), which has now been upheld by the Apex Court in the case of Queen's Educational Society (supra). However, it is also to be noted that a Division Bench of this Court in CIT v. Surya Educational & Charitable Trust[2013] 355 ITR 280/[2011] 203 Taxman 53/15 taxmann.com 123 (Punj. & Har.), subsequently, held that the princ…

M/S STEP BY STEP JUNIOR SCHOOL SOCIETY,AMRITSAR. vs. COMMISSIONER OF INCOME TAX (EXEMPTION), CHANDIGARH

ITA 596/ASR/2016[2015-16]Status: DisposedITAT Amritsar16 Aug 2021AY 2015-16

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 10

…shwar Shiksha Samiti vs. CIT(E) Chandigarh in ITA No. 670(ASR)/2015 order dated 30/08/2017 relating to AY 2015-16. 9. Decision of Punjab & Haryana High Court in the case of Pinegrove International Charitable Trust and Ors vs Union of India and Ors reported in 327 ITR 73. ITA 596/Amr/2016 9 10. Decision of Punjab & Haryana High Court in the case of CIT(E) Chandigarh vs. Shree Mahavir Jain Society (Regd.) in Appeal No. 231 of 2016 order dated 11/09/2017. 17. On the contrary, the learned D.R. for the revenue had submitted that Section 10 (23C) (vi) of the Act would only be applicable if the assessee is running the…