Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education v. ITO (86 ITR 408)

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

…the decisions in Sole Trustee (1975) 101 ITR 234 (SC), Assam Text Book Production & Publication Corporation Limited vs. CIT (2009) 319 ITR 317 (SC), CIT vs. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 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' occu…

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

…the decisions in Sole Trustee (1975) 101 ITR 234 (SC), Assam Text Book Production & Publication Corporation Limited vs. CIT (2009) 319 ITR 317 (SC), CIT vs. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 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' occu…

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

…आयकर अऩीऱीय अधधकरण, रायऩुर न्यायऩीठ, रायऩुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR श्री रविश सूद, न्याययक सदस्य एवं श्री अरुण खोड़वऩया, ऱेखा सदस्य के समक्ष । BEFORE SHRI RAVISH SOOD, JM & SHRI ARUN KHODPIA, AM आयकर अऩीऱ सं./ITA No.15/RPR/2017 (ननधाारण वषा / Assessment Year :NA) The Radiant Way School, Vs CCIT, Raipur C/o Shree Mangal Dube Memorial Education Society, Pt. Ravishankar University Campus Raipur PAN No. : AAMTS 3251 M (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee by : Shri Abhishek Mahawar, CA राजस्व की ओर से /Revenue by : Shri P.K.Mishra, CIT-DR सुनिाई…

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

…the decisions in Sole Trustee (1975) 101 ITR 234 (SC), Assam Text Book Production & Publication Corporation Limited vs. CIT (2009) 319 ITR 317 (SC), CIT vs. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 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' occu…

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)

…the decisions in Sole Trustee (1975) 101 ITR 234 (SC), Assam Text Book Production & Publication Corporation Limited vs. CIT (2009) 319 ITR 317 (SC), C1T vs. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 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' occu…

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 241/DEL/2018[2012-13]Status: DisposedITAT Delhi09 Dec 2020AY 2012-13

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)

…the decisions in Sole Trustee (1975) 101 ITR 234 (SC), Assam Text Book Production & Publication Corporation Limited vs. CIT (2009) 319 ITR 317 (SC), C1T vs. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 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' occu…

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 240/DEL/2018[2011-12]Status: DisposedITAT Delhi09 Dec 2020AY 2011-12

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)

…the decisions in Sole Trustee (1975) 101 ITR 234 (SC), Assam Text Book Production & Publication Corporation Limited vs. CIT (2009) 319 ITR 317 (SC), C1T vs. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education vs. ITO (1972) 86 ITR 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' occu…

RAJASTHAN STATE TEXT BOOK BOARD,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION)-CIRCLE, JAIPUR

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

ITA 252/JPR/2019[2013-14]Status: DisposedITAT Jaipur10 Apr 2019AY 2013-14

Bench: Or At The Time Of Hearing.”

For Appellant: Shri Vinod Gupta (C.A.)For Respondent: Shri Varinder Mehta (CIT)

Section 10Section 10(22)Section 143(3)

…isting solely for the purpose of education, within the meaning of s. 10(22) of the Act. Further, reference was made to a decision of Rajasthan State text Book Board vs. ACIT(E) the Orissa High Court, in the case of Board of Secondary Education vs. ITO (1972) 86 ITR 408 (Ori) : TC 32R.757 dealing with similar facts. 3. It is not disputed before us that the aims and objects of the Tamil Nadu Text Book Society and that of the respondent- assessee are almost identical. It is also not shown to us that the surplus amount, it any, of the respondent-assessee, is used for any other purpose or distributed to other member…

GAUSHALA TRUST SOCIETY,AMBALA CITY vs. CIT(E), CHANDIGARH

In the result, the appeal of the assessee, therefore,

ITA 1185/CHANDI/2017[2017-08]Status: DisposedITAT Chandigarh11 Jul 2018AY 2017-08

Bench: Shri Sanjay Garg & Ms. Annapurna Guptagaushala Trust Society, Vs. The Cit(Exemptions), Spatu Road, Central Revenue Building, Ambala City. 5Th Floor, Sector-17E, Chandigarh. Pan: Aabag6754D (Appellant) (Respondent)

For Appellant: Shri Rohit Goyal, CAFor Respondent: Shri Gulshan Raj, CIT DR

Section 11Section 11(1)(d)Section 12A

…me. Reliance was placed by the Ld. counsel for assessee on the following judgments of the Hon'ble High Court in support of its contention: 1) CIT Vs. Delhi Kannada Education Society 246 ITR 731 (Delhi HC) 2) Secondary Board of Education Orissa Vs. ITO (1972) 86 ITR 408 (Orissa HC) 3) DIT(Exemptions), Mumbai Vs. Shree Nashik Panchvati Panjrapole (2017) 397 ITR 501 4) DIT(Exemptions Vs. Sabarmati Ashram Gaushala Trust (2014) 362 ITR 539 13. The Ld. DR, on the other hand, relied upon the order of the Ld.CIT(E). 14. We have heard the rival contentions, and also carefully gone through the documents and case laws…

LN HOTA & COMPANY,CUTTACK vs. ACIT, CUTTACK

In the result, the appeals filed by the assessee are dismissed

ITA 572/CTK/2013[2007-08]Status: DisposedITAT Cuttack31 May 2017AY 2007-08

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

For Appellant: Shri S.K.Jena, ARFor Respondent: Shri Kunal Singh, CIT, DR/ D.K.Pradhan, DR

Section 10Section 143(3)

…ons filed by the assessee observed that the assessee is emphasising that it has obtained approval under the prevailing law under section 10(22) of the Act and referred to the decision of Hon’ble High Court of Orissa in assessee’s own case reported in (1972) 86 ITR 408 (Ori), wherein, the Hon’ble High Court considered the facts and objects of the assessee Board and gave a finding that any income of an University or other educational institution, existing for educational purposes and not for the purposes of profit is exempted from tax u/s.10(22) of the Act. Therefore, the income derived by the assessee is claim…

BOARD OF SECONDARY EDUCATION,CUTTACK vs. ITO, CUTTACK

In the result, the appeals filed by the assessee are dismissed

ITA 601/CTK/2005[2002-03]Status: DisposedITAT Cuttack17 May 2017AY 2002-03

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

For Appellant: Shri S.K.Jena, ARFor Respondent: Shri Kunal Singh, CIT, DR/ D.K.Pradhan, DR

Section 10Section 143(3)

…sions filed by the assessee observed that the assessee is emphasising that it has obtained approval under the prevailing law under section 10(22) of the Act and referred to the decision of Hon’ble High Court of Orissa in assessee’s own case reported in (1972) 86 ITR 408 (Ori), wherein, the Hon’ble High Court considered the facts and objects of the assessee Board and gave a finding that any income of an University or other educational institution, existing for educational purposes and not for the purposes of profit is exempted from tax u/s.10(22) of the Act. Therefore, the income derived by the assessee is claimed…

DELHI BUREAU OF TEXT BOOKS vs. DIRECTOR OF INCOME TAX(E)

The appeals are allowed but, in the circumstances, with no orders as to costs

ITA/807/2015HC Delhi03 May 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 12ASection 2Section 260

…en by the Gauhati High Court which, incidentally, was followed by the ITAT in the present case. Ms. Bansal also placed reliance on the decisions in CIT v. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education v. ITO (1972) 86 ITR 408 (Ori). 15. Referring to the decision of the Supreme Court in ACIT v. Surat City Jimkhana (supra) Ms. Bansal submitted that once the registration of a trust under Section 12 A of the IT Act is given the AO cannot thereafter make a further probe into the purposes of the entity. She also referred to the decision in Hiralal Bhagwati v. CIT (200…

DELHI BUREAU OF TEXT BOOKS vs. DIRECTOR OF INCOME TAX(E)

The appeals are allowed but, in the circumstances, with no orders as to costs

ITA/812/2015HC Delhi03 May 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 12ASection 2Section 260

…en by the Gauhati High Court which, incidentally, was followed by the ITAT in the present case. Ms. Bansal also placed reliance on the decisions in CIT v. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education v. ITO (1972) 86 ITR 408 (Ori). 15. Referring to the decision of the Supreme Court in ACIT v. Surat City Jimkhana (supra) Ms. Bansal submitted that once the registration of a trust under Section 12 A of the IT Act is given the AO cannot thereafter make a further probe into the purposes of the entity. She also referred to the decision in Hiralal Bhagwati v. CIT (200…

DELHI BUREAU OF TEXT BOOKS vs. DIRECTOR OF INCOME TAX (E)

The appeals are allowed but, in the circumstances, with no orders as to costs

ITA/811/2015HC Delhi03 May 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 12ASection 2Section 260

…en by the Gauhati High Court which, incidentally, was followed by the ITAT in the present case. Ms. Bansal also placed reliance on the decisions in CIT v. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education v. ITO (1972) 86 ITR 408 (Ori). 15. Referring to the decision of the Supreme Court in ACIT v. Surat City Jimkhana (supra) Ms. Bansal submitted that once the registration of a trust under Section 12 A of the IT Act is given the AO cannot thereafter make a further probe into the purposes of the entity. She also referred to the decision in Hiralal Bhagwati v. CIT (200…

DELHI BUREAU OF TEXT BOOKS vs. DIRECTOR OF INCOME TAX (E)

The appeals are allowed but, in the circumstances, with no orders as to costs

ITA/810/2015HC Delhi03 May 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 12ASection 2Section 260

…en by the Gauhati High Court which, incidentally, was followed by the ITAT in the present case. Ms. Bansal also placed reliance on the decisions in CIT v. Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education v. ITO (1972) 86 ITR 408 (Ori). 15. Referring to the decision of the Supreme Court in ACIT v. Surat City Jimkhana (supra) Ms. Bansal submitted that once the registration of a trust under Section 12 A of the IT Act is given the AO cannot thereafter make a further probe into the purposes of the entity. She also referred to the decision in Hiralal Bhagwati v. CIT (200…

Rajasthan State Text Book Board (2000) 244 CTR 667 (Raj), Secondary Board of Education v. ITO

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