How many judgments cite Queen’s Educational Society v. CIT?

152 judgments on BharatTax cite Queen’s Educational Society v. CIT (372 ITR 699), spanning 2011 to 2026.

Which sections of the Income Tax Act does Queen’s Educational Society v. CIT come up under?

It is most often cited in judgments turning on Section 11, Section 12AA, Section 143(3), Section 142(1), Section 2(15), Section 10(23C)(v).

Queen’s Educational Society v. CIT

372 ITR 699Supreme Court of India2015#650 most cited

What is Queen’s Educational Society v. CIT authority for?

An educational institution that generates a surplus does not automatically lose its charitable status or cease to exist solely for educational purposes. This is true if the surplus is reinvested for its educational objectives, and the predominant object test determines if the institution's primary aim is education or profit.

152

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2026.

Also referred to as

Queen's Educational Society v. CIT · Section 11 · Section 10(23C) · Section 2(15) · Section 12A · educational institution surplus · charitable purpose profit motive · predominant object test · income tax exemption

Also reported as

55 Taxmann.com 255

Sections most often in play

Section 11 Section 12AA Section 143(3)Section 142(1)Section 2(15)Section 10(23C)(v)Section 12A Section 139(4A)

Issues it is cited on

section 13(1)(c)(ii)section 10(22)section 158a section 13(3)section 10(23c)(vi)proviso to section 2(15)section 13(1)(c)section 13(1)interest free advances section 10(23c)section 2(15)application of income

Judgments citing Queen’s Educational Society v. CIT

MAHA ACADAMY OF PEDIATRIC NEUROLOGY,NAGPUR vs. CIT(EXEMPTION), PUNE

In the result, appeal filed by the assessee stands allowed

ITA 217/NAG/2025[2025-26]Status: DisposedITAT Nagpur26 Mar 2026AY 2025-26

Bench: Shri Pawan Singh & Shri Khettra Mohan Roymaha Academy Of Pediatric Cit (Exemptions), Pune Neurology, Plot No.7, Block Vs Nos. 2, 3, 4, 5, Guru Balawantsing Compound, Near Lokmat Building, Patwardhan Ground, Nagpur-440012. Pan : Aaqam 4626 H Assessee Respondent Assessee By : Shri Pranav Ashtikar, Ca Revenue By : Shri Pankaj Kumar, Cit-Dr Date Of Hearing : 24.02.2026 Date Of Pronouncement : 26.03.2026

For Appellant: Shri Pranav Ashtikar, CAFor Respondent: Shri Pankaj Kumar, CIT-DR

Section 12Section 12ASection 12A(1)(ac)

…f surplus from an educational activity does not imply profit motive, so long as the surplus is applied solely towards the objects of the trust. This legal position has been clearly enunciated by the Hon’ble Supreme Court in Queen’s Educational Society v. CIT (372 ITR 699), wherein it was held that when surplus is ploughed back into educational purposes, the institution exists solely for education and not for profit. 20. In the present case, there is no material on record to suggest that any part of the income or property of the trust was diverted for private benefit. All receipts, including sponsorships and deleg…

THE INSTITUTE OF MARINE ENGINEERS INDIA ,MUMBAI vs. ITO WARD 2(4), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 5666/MUM/2025[2009-10]Status: DisposedITAT Mumbai17 Dec 2025AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Karthik Natarajan, CAFor Respondent: Shri Virabhadra Mahajan, SR DR

Section 11Section 143(3)Section 250Section 254

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C”, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A No.5666/Mum/2025 (Assessment Year: 2009-10) The Institute of Marine vs Income-tax Officer, Ward 2(4), Engineers India, Mumbai, Room NO.699, 6th Floor IMEI House, Sector 19, Plot 94, Nerul, Navi Mumbai – 400 706 MTNL Bldgh, Cumballa Hill, Peddar PAN : AAATT3254B Road, Mumbai-400 026 APPELLANT RESPONDENT Assessee by : Shri Karthik Natarajan, CA Respondent by : Shri Virabhadra Mahajan, SR DR Date of hearing : 11/11/2025 Date of pronouncement : 17/12/202…

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

…me\nof trust including hostel and transportation receipts—Assessee's ground allowed.\nReliance is further placed on the decision of Hon'ble Apex Court in the case of\nQueen Educational Society v/s CIT, (2015) 275 CTR (SC) 449 : (2015) 117 DTR (SC) 1\n: (2015) 372 ITR 699 (SC): (2015) 231 Taxman 286 (SC) in which it was held as\nunder:\nExemption under ss.10(23C)(iiiad) and 10(23C)(vi)—Educational institution—Profit\nmotive-Where an educational institution carries on the activity of education\nprimarily for educating persons, the fact that it makes a surplus does not lead to\nthe conclusion that it has ceased to e…

NEURO UPDATE CHENNAI,CHENNAI vs. ITO, EXEMPTION WARD-1, CHENNAI

In the result, the appeal of the assessee is allowed

ITA 1480/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Oct 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri S.R.Raghunatha

For Appellant: Shri. G. Sitharaman, CA &For Respondent: Shri. R. Raghupathy, Addl. C.I.T

Section 11Section 12ASection 2(15)Section 250

…nal activities, not passive support. Hence, this decision is also factually inapplicable 17. The Appellant places reliance on the following cases: a. The decision of the Supreme Court of India in Queen's Educational Society v Commissioner of Income Tax (2015) 372 ITR 699 wherein it was held in Paragraph 19 that "It is clear that when a surplus is ploughed back for educational purposes the educational institution exists solely for educational purposes and not for purposes of profit." (from pages 18 to 20). Thus, the mere generation of surplus shall not result in the main object of the trust being nullified and doe…

MADHAV UNIVERSITY,PINDWARA, SIROHI vs. CIT(EXEMPTION), JAIPUR

In the result, both the appeals filed by the assessee bearing ITA No

ITA 789/JODH/2024[2024-25]Status: DisposedITAT Jodhpur22 Aug 2025AY 2024-25

Bench: Dr. Mitha Lal Meena, Hon'Ble & Shri Anikesh Banerjee, Hon'Bleι.Τ.Α No.789 &790/Jodh/2024 (Assessment Year:2024-25) Madhav University Vs Commissioner Of Income-Tax, Exemption, Jaipur Pindwara, Madhav Hills, Nh 27, Vpo Bharja, Pindwara, Sirohi Rajasthan-307023 Pan: Aasam7855L Shri Amit Kothari Shri M.K. Jain, Cit(Dr.) Present For Assessee Present For Revenue Date Of Hearing 20/08/2025 Date Of Pronouncement 22/08/2025 Order Per Bench: The Instant Appeals Of The Assessee Filed Against The Order Of The Learned Commissioner Of Income-Tax (Exemption), Jaipur (For Brevity, 'Ld.Cit(E)'] Order Passed Under Section 12Ab Of The Income-Tax Act, 1961 (In Short, 'The Act') & Order Passed Under Section 80G(5) Of The Act, Date Of Orders 30/09/2024. 2. Act Both The Appeals Related To Registration Under Section 12Ab& 80G Of The

Section 11Section 12ASection 3(2)Section 80Section 80G(5)

…ary and fully ploughed back into educational infrastructure in subsequent years. 4. In 2022-23 and 2023-24, the appellant applied more than 100% of its income, drawing from reserves to fund expansion. 4.5. Judicial Support: Queen's Educational Society v. CIT (372 ITR 699, SC)- surplus permissible if applied to objects. Exemption under ss. 10(23C)(iiiad) and 10(23C)(vi)-Educational institution-Profit motive- Where an educational institution carries on the activity of education primarily for educating persons, the fact that it 8 makes a surplus does not lead to the conclusion that it has ceased to exist solely for…

JUSCO EDUCATION MISSION FOUNDATION ,JAMSHEDPUR vs. DCIT EXEMPTION CIRCLE , RANCHI

In the result, this appeal of assessee is allowed

ITA 2/RAN/2018[14-15]Status: DisposedITAT Ranchi30 May 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 11Section 12ASection 143(3)Section 144ASection 2(15)Section 234B

…IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER I.T.A. No. 02/Ran/2018 (Assessment Year-2014-15) (Virtual Hearing) JUSCO Education Mission Foundation, DCIT, JUSCO Ltd., Sakchi Bulevard Road, Exemption Circle, Vs. Bistupur, Jamshedpur-831001. Ranchi. PAN No. AABTJ 0368 F Appellant/ Assessee Respondent/ Revenue Assessee represented by Shri R.R. Mittal, A.R. Department represented by Shri Khubchand T. Pandya, Sr.DR Date of hearing 24/04/2025 Date of pronouncement 24/04/2025 O R D E R PER: BENCH 1. This appeal by t…

ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTION CIRCLE, AURANGABAD, NEAR HOLY CROSS ENGLISH SCHOOL vs. THE NANDED SIKHGURUDWARA SACHKHAND HAZUR SAHIB, ABCHALNAGAR

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

ITA 809/PUN/2024[2017-18]Status: DisposedITAT Pune26 May 2025AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar CIT-DR

Section 10Section 139Section 143(2)

…funds of 41% of gross receipts and inferred that the funds were not utilized for the object for which the respondent-assessee trust was formed. The Hon'ble Supreme Court in the case of Queen's Educational Society v CIT [2015] 55 taxmann.com 255/231 Taxman 286/372 ITR 699 held that merely because a charitable trust had generated surplus does not lead to conclusion that the appellant trust is not charitable or religious exiting for the purpose of profit. To the similar effect in the decision of the Hon'ble Supreme Court in the case of Aditanar Educational Institution v. Addl. CIT [1997] 90 Taxman 528/224 ITR 310. T…

ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTION CIRCLE, AURANGABAD, NEAR HOLY CROSS ENGLISH SCHOOL vs. THE NANDED SIKHGURUDWARA SACHKHAND HAZUR SAHIB, APCHALNAGAR

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

ITA 808/PUN/2024[2016-17]Status: DisposedITAT Pune26 May 2025AY 2016-17

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar CIT-DR

Section 10Section 139Section 143(2)

ITI EDUCATION COMMITTE ,BENGALURU vs. INCOME TAX OFFICER, WARD-1, BENGALURU

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

ITA 563/BANG/2024[2014-15]Status: DisposedITAT Bangalore19 Aug 2024AY 2014-15

Bench: Shri George George K & Shri Waseem Ahmedassessment Year : 2014-15

For Appellant: Shri Shambu Sharma, C.AFor Respondent: Ms. Matta Padma, Addl. CIT (DR)

Section 10Section 11Section 12A

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND SHRI WASEEM AHMED, ACCOUNTANT MEMBER Assessment Year : 2014-15 ITI Education Committee, Vs. The Income Tax Officer Vidyamandir, Dooravaninagar, (Exemption), Bengaluru-560 016 Ward - 1, Bengaluru. PAN – AAAAI 0748 L APPELLANT RESPONDENT Assessee by : Shri Shambu Sharma, C.A Revenue by : Ms. Matta Padma, Addl. CIT (DR) Date of hearing : 06.06.2024 Date of Pronouncement : 19.08.2024 O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the order passed by the N…

DY. COMMISSIONER OF INCOME TAX (E)-2(1), MUMBAI, MUMBAI vs. THE CATHEDRAL VIDYA TRUST, MUMBAI

In the result, the appeal filed by the revenue is dismissed

ITA 3292/MUM/2023[2014-15]Status: DisposedITAT Mumbai27 Jun 2024AY 2014-15

Bench: Shri Amit Shukla & Smt. Renu Jauhri

For Appellant: Shri. Ronak Doshi & Ms. Mahek SavlaFor Respondent: Shri. H. M. Bhatt

Section 11Section 12ASection 13(3)Section 143(3)

…not impugn upon the eligibility for exemption under section 11 of the Act. The fee is charging for fulfilment of its object and in support of his contention, the Id. AR of the assessee relied upon the following decisions; i. Queen's Education Society vs. CIT (372 ITR 699) (SC). ii. Vanita Vishram Trust vs. CCIT (327 ITR 121) (Bom.HC). iii. Tolani Education Society vs. DDIT (351 ITR 184) (Bom.HC). iv. Green Acres Educational Trust vs. DCIT (70 taxmann.com 347) (Mum. Trib.) V. Gagan Education Society vs. ACIT (10 taxmann.com 156) (Agra Trib.) vi. ACIT vs. Mahima Shiksha Samiti (79 taxmann.com 38) (Jaipur Trib.). T…

COMMISSIONER OF INCOME-TAX, PATIALA vs. YOUNG SCHOLARS EDUCAITON SOCIETY, BARNALA

ITA/21/2011HC Punjab & Haryana08 May 2024

Bench: This Court Under Section 260A Of The Income Tax Act, 1961 (Hereinafter To Be Referred As “The Act”) Against The Order Dated 16.07.2010 Passed By The Income Tax Appellate Tribunal, Chandigarh Bench-A, Chandigarh (Hereinafter To Be Referred As “The Itat”) In Ita No. 510/Chd/2010 - M/S Young Scholars Educational Society, Barnala Vs Cit, Patiala, Whereby The Order Dated 26.03.2010 Passed By The Commissioner Of Income Tax, Patiala (Hereinafter To Be Referred As “The Commissioner”) Was Quashed & The Varinder Singh 2024.05.13 10:09 I Attest To The Accuracy & Authencity Of This Order/Judgment

Section 12ASection 2(15)Section 260A

…nternational Chairtable Trust vs Union of India and others (2010) 327 ITR (P&H) before Hon’ble the Supreme Court. Hon’ble the Supreme Court has, however, finally adjudicated the law in Queen’s Educational Society vs Commissioner of Income Tax (2015) 372 ITR 699 (SC) while upholding Pinegrove’s case (supra). The following substantial questions of law were framed in the appeals:- (i) Whether in the facts and circumstances of the case, the ITAT was legally correct in quashing the order dated 02.03.2010 passed by the CIT cancelling the registration granted u/s 12A merely on technical grounds and without go…

HIMACHAL PRADESH TECHNICAL UNIVERSITY ,HAMIRPUR vs. CIT(E), CHANDIGARH

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

ITA 115/CHANDI/2020[-]Status: DisposedITAT Chandigarh28 Mar 2024

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Amitoz Singh Kamboj, CAFor Respondent: Shri Rohit Sharma, CIT DR

Section 10

…आयकर अपीलीय अिधकरण,च"डीगढ़ "यायपीठ “ए” , च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: VIRTUAL MODE "ी आकाश दीप जैन, उपा"य" एवं "ी िव"म "सह यादव, लेखा सद"य BEFORE: SHRI. AAKASH DEEP JAIN, VP & SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं./ ITA NO. 115/Chd/2020 िनधा"रण वष" / Assessment Year : Himachal Pradesh Technical बनाम CIT(E) University Chandigarh Old SDM Office, Gandhi Chowk, Hamirpur H.P. "थायी लेखा सं./PAN NO: AAATH9345M अपीलाथ"/Appellant ""यथ"/Respondent िनधा"रती क" ओर से/Assessee by : Shri Amitoz Singh Kamboj, CA राज"व क" ओर से/ Revenue by : Shri Rohit Sharma,…

ASHWINI SAHAKARI RUNGNALAYA & RESEARCH CENTER,,SOLAPUR vs. COMMISSIONER OF INCOME-TAX, (EXEMPTIONS),, PUNE

ITA 714/PUN/2018[N.A]Status: DisposedITAT Pune07 Mar 2024

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 714/Pun/2018 Ashwini Sahakari Rugnalaya & Research Centre 7107/1, Plot No. 180, North Sadar Bazar, Solapur-413003. Pan: Aaaja0041K . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Pramod Shingte [‘Ld. AR’]For Respondent: Mr Keyur Patel [‘Ld. DR’]

Section 10Section 10(23)Section 11Section 12ASection 22Section 253(1)(c)

…e Education Society Vs CCIT’ [2022] 143 Taxmann.com 276 (SC) ‘ACIT Vs Surat Art Silk Cloth Manufacturers Association’ 121 ITR 1 (SC) and in ‘Queens Educational Society Vs CIT’ ITAT-Pune Page 23 of 66 Ashwini Sahakari Rugnalaya & Research Centre reported in 372 ITR 699, ‘Thiagarajar Charities Vs ACIT’ 225 ITR 1010 (SC) wherein their Hon’ble Lordship have laid that, in determining the true nature of existence of an entity what is necessary to be considered is whether having regard to all the facts and circumstances of the case, the dominant object of the activity is profit-making or carrying out a charitable pur…

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

ITA 745/BANG/2023[2018-19]Status: DisposedITAT Bangalore03 Jan 2024AY 2018-19

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

Section 11Section 2(15)Section 234ASection 8

…re fact that the activities of the trust yield profit will not alter the charitable character of the trust." ix. The 1d. A.R. placed further reliance on the decision of the Hon'ble Apex Court in the case of Queens Educational Society v. CIT reported in [2015] 55 Taxmann.com 255(SC) wherein it was held; (1) Where an educational institution carries on the activity of education primarily for educating persons, the fact that it makes incidental surplus does not lead to the conclusion that it ceases to exist solely for educational purposes and becomes an institution for the purpose of making profit. (2) The predominan…

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

ITA 744/BANG/2023[2016-17]Status: DisposedITAT Bangalore03 Jan 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

For Appellant: Shri Ravishankar, A.RFor Respondent: Shri D.K. Mishra, D.R

Section 11Section 2(15)Section 234ASection 8

…e fact that the activities of the trust yield profit will not alter the charitable character of the trust.” ix. The ld. A.R. placed further reliance on the decision of the Hon’ble Apex Court in the case of Queens Educational Society v. CIT reported in [2015] 55 Taxmann.com 255(SC) wherein it was held; (1) Where an educational institution carries on the activity of education primarily for educating persons, the fact that it makes incidental surplus does not lead to the conclusion that it ceases to exist solely for educational purposes and becomes an institution for the purpose of making profit. (2) The predomina…

DCIT , CHENNAI vs. M/S SINDHI EDUCATIONAL SOCIETY ( MADRAS ), CHENNAI

In the result, appeals filed by the Revenue for all the assessment

ITA 981/CHNY/2022[2019-2020]Status: DisposedITAT Chennai15 Sept 2023AY 2019-2020

Bench: Shri. V. Durga Rao, Hon’Ble & Shri. Manjunatha. G, Hon’Ble

For Respondent: Mr.P. Sajit Kumar, JCIT

Section 11Section 11(1)(d)Section 2(24)(iia)

…ions cannot be construed as for the purpose of charitable objective and also not in the character of voluntary contributions u/s.2(24)(iia). 2.7 The CIT(A) erred in holding that the decision of the Supreme Court in the case of Queens Elizabeth Society Vs CIT 372 ITR 699 is squarely applicable to the facts of the case and theory of capitation fee referred cannot be equated with the "Corpus donations" in the case of assessee. Since the corpus donations are not voluntary in nature and they are nothing but capitation fee, the assessee should not be given benefit of Sec.11 of the Act. ITA Nos.975 to 981/Chny/2022 ::…