Sole Trustee, Loka Shikshana Trust v. CIT

101 ITR 234Supreme Court of India1975#231 most cited

What is Sole Trustee, Loka Shikshana Trust v. CIT authority for?

This case defines 'education' under Section 2(15) of the Income Tax Act as systematic instruction, schooling, or training given to the young for preparation for the work of life. It clarifies that 'education' in this context has a narrow meaning, not extending to every acquisition of further knowledge.

323

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also referred to as

Sole Trustee Loka Shikshana Trust v CIT · 101 ITR 234 · definition of education · section 2(15) education · scope of education · charitable purpose · section 11 exemption · systematic instruction · schooling · training · narrow meaning of education

Sections most often in play

Section 2(15)Section 11Section 12AASection 80GSection 12ASection 12Section 11(1)(a)Section 12AB

Issues it is cited on

section 52(2)section 10(22)advancement of general public utilitysection 52proviso to section 2(15)section 2(15)section 10(23c)(vi)section 10(23c)section 11(1)(a)section 11(1)section 12aaregistration under section 12a

Judgments citing Sole Trustee, Loka Shikshana Trust v. CIT

DESHPANDE EDUCATIONAL TRUST,HUBLI vs. DCIT, EXEMPTIONS CIRCLE-1, MANGALORE

In the result, Appeal of the Assessee is allowed as indicated above

ITA 3101/BANG/2025[2017-18]Status: DisposedITAT Bangalore15 Apr 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

For Appellant: Shri L. Bharath, CA
Section 11Section 147Section 2(15)

…contentions of the Assessee holding that Assessee is carrying on activities of advancement of any other object of general public utility and not formal education. Therefore, relying upon the decision of the Hon’ble Supreme Court in case of Lok Shikshana Trust 101 ITR 234 did not allow the exemption u/s. 11 and 12 of the Act. The Assessing Officer further noted that Assessee Trust has paid service tax to the tune of Rs. 12,39,293/- which clearly shows that the Trust is running commercial activity and not charitable activities. Accordingly, the Assessment Order was passed at a total income of Rs. 1,50,60,860/-. 9.…

DESHPANDE EDUCATIONAL TRUST,HUBLI vs. DCIT, EXEMPTIONS CIRCLE-1, MANGALORE

In the result, Appeal of the Assessee is allowed as indicated above

ITA 3100/BANG/2025[2016-17]Status: DisposedITAT Bangalore15 Apr 2026AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

For Appellant: Shri L. Bharath, CA
Section 11Section 147Section 2(15)

…contentions of the Assessee holding that Assessee is carrying on activities of advancement of any other object of general public utility and not formal education. Therefore, relying upon the decision of the Hon’ble Supreme Court in case of Lok Shikshana Trust 101 ITR 234 did not allow the exemption u/s. 11 and 12 of the Act. The Assessing Officer further noted that Assessee Trust has paid service tax to the tune of Rs. 12,39,293/- which clearly shows that the Trust is running commercial activity and not charitable activities. Accordingly, the Assessment Order was passed at a total income of Rs. 1,50,60,860/-. 9.…

DESHPANDE EDUCATIONAL TRUST,HUBLI vs. DCIT, EXEMPTIONS CIRCLE-1, MANGALORE

In the result, Appeal of the Assessee is allowed as indicated above

ITA 3099/BANG/2025[2015-16]Status: DisposedITAT Bangalore15 Apr 2026AY 2015-16

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

For Appellant: Shri L. Bharath, CA
Section 11Section 147Section 2(15)

…contentions of the Assessee holding that Assessee is carrying on activities of advancement of any other object of general public utility and not formal education. Therefore, relying upon the decision of the Hon’ble Supreme Court in case of Lok Shikshana Trust 101 ITR 234 did not allow the exemption u/s. 11 and 12 of the Act. The Assessing Officer further noted that Assessee Trust has paid service tax to the tune of Rs. 12,39,293/- which clearly shows that the Trust is running commercial activity and not charitable activities. Accordingly, the Assessment Order was passed at a total income of Rs. 1,50,60,860/-. 9.…

ASHOK GONDHIA MEMORIAL TRUST,RAJKOT vs. THE ITO EXEMPTION, WARD -1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

ITA 112/RJT/2026[2015-16]Status: DisposedITAT Rajkot10 Apr 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr.DR
Section 11Section 143(3)Section 144Section 250

…Technical institute (120 ITR 358) is also .incorrect since the said decision has since been reversed by the Hon. Supreme Court in 188 ITR 57.The AO's reliance on the decision of the Hon. Supreme Court in the case of Sole Trustee Lok Shikshana Trust V/s CIT ( 101 ITR 234) is also incorrect on facts apart from the facts that a major part of the said decision has since been overruled by a larger bench of the Hon, Supreme Court in the case of Addl CIT V/s Surat Art Silk Cloth Manufacturer Association (121 ITR 1 SC). This apart the case of Lok Shikshana Trust dealt with a wholly different issue where a sole trustee h…

VYASA VIDYA MANDIRAM,COIMBATORE vs. CIT, EXEMPTIONS,, CHENNAI

ITA 1287/CHNY/2025[-]Status: DisposedITAT Chennai09 Mar 2026
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

…, in order dated 21.03.2025. The main reasons for rejection are enlisted below: A. The Trust is conducting vedic courses in an unorganized way which is against the dictum laid down by the Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT (101 ITR 234). Further, the Supreme Court in the case of New Noble Education Society v. CCIT (143 taxmann.com 276) reaffirmed the narrow and restricted meaning of the term 'Education' to a scholastic structured learning as confined (sic.-construed) in Articles 21A, 29-30 and 45-46 of the Constitution of India. B. The Trust is collecting fees for conducting un…

YAKSHIT YUVA FOUNDATION,BELAGAVI vs. CIT (EXEMPTION), BENGALURU

Appeals stands Allowed

ITA 234/PAN/2025[80G]Status: DisposedITAT Panaji06 Mar 2026

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 233 & 234/Pan/2025 Yakshit Yuva Foundation O/O Taekwondo Master Rao, 1St Fl, Gadekar Complex, P B Road, Kakati S.O., Belagavi. Pan : Aaaty9435D . . . . . . . Appellant V/S The Commissioner Of Income Tax, Exemption, Bangalore. . . . . . . . Respondent

For Appellant: Mr Shreepada Ravi Rao [‘Ld. AR’]For Respondent: Mr Azar Zain [‘Ld. DR’]
Section 12ASection 12A(1)(ac)Section 2(15)Section 80GSection 80G(5)(iii)

…e activity of sports training as whether it constitutes education, we note that the term ‘education’ has not been defined in the Act, however it has been interpreted in context of section 2(15) by the Hon'ble Apex Court in ‘Loka Shikshana Trust Vs CIT’ [1975, 101 ITR 234 (SC)]. The Hon’ble lordship therein held that; ‘what education connotes in that clause 2(15) is the process of training and developing the knowledge, skill, mind and character of students by normal schooling.' It clearly emerges from former factual narration of hon’ble lordship that; so long as assessee is engaged into developing any knowledge or…

YAKSHIT YUVA FOUNDATION,BELAGAVI vs. CIT (EXEMPTION), BENGALORE

Appeals stands Allowed

ITA 233/PAN/2025[12AB]Status: DisposedITAT Panaji06 Mar 2026

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 233 & 234/Pan/2025 Yakshit Yuva Foundation O/O Taekwondo Master Rao, 1St Fl, Gadekar Complex, P B Road, Kakati S.O., Belagavi. Pan : Aaaty9435D . . . . . . . Appellant V/S The Commissioner Of Income Tax, Exemption, Bangalore. . . . . . . . Respondent

For Appellant: Mr Shreepada Ravi Rao [‘Ld. AR’]For Respondent: Mr Azar Zain [‘Ld. DR’]
Section 12ASection 12A(1)(ac)Section 2(15)Section 80GSection 80G(5)(iii)

…e activity of sports training as whether it constitutes education, we note that the term ‘education’ has not been defined in the Act, however it has been interpreted in context of section 2(15) by the Hon'ble Apex Court in ‘Loka Shikshana Trust Vs CIT’ [1975, 101 ITR 234 (SC)]. The Hon’ble lordship therein held that; ‘what education connotes in that clause 2(15) is the process of training and developing the knowledge, skill, mind and character of students by normal schooling.' It clearly emerges from former factual narration of hon’ble lordship that; so long as assessee is engaged into developing any knowledge or…

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, EXEMPTIONS, CIRCLE-1, , BANGALORE

ITA 355/BANG/2024[2017-18]Status: DisposedITAT Bangalore02 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR
Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH : BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER ITA Nos. 354 & 355/Bang/2024 Assessment Years : 2016-17 & 2017-18 M/s. Karnataka Industrial Areas Development Board, No. 49, 4th & 5th Floors, Khanija Bhavan, Race Course Road, Bangalore – 560 001. PAN: AAATK1305J APPELLANT The Deputy Commissioner of Income Tax, Exemptions Circle – 1, Vs. Bangalore. RESPONDENT Assessee by : Shri Sudheendra B.R, Advocate Revenue by : Shri Shivanand H Kalakeri, CIT-DR Date of Hearing : 02-12-2025 Date of Pronouncement : 02-03-2026 ORDER…

KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, BANGALORE

ITA 354/BANG/2024[2016-17]Status: DisposedITAT Bangalore02 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR
Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

…Page 1 of 34 ITA Nos. 354 & 355/Bang/2024 IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH : BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER ITA Nos. 354 & 355/Bang/2024 Assessment Years : 2016-17 & 2017-18 M/s. Karnataka Industrial Areas Development Board, No. 49, 4th & 5th Floors, Khanija Bhavan, Race Course Road, Bangalore – 560 001. PAN: AAATK1305J APPELLANT The Deputy Commissioner of Income Tax, Exemptions Circle – 1, Vs. Bangalore. RESPONDENT Assessee by : Shri Sudheendra B.R, Advocate Revenue by : Shri Shivanand H Kalakeri, CIT-DR Date of Hearing : 02-12-2025…

JERMELS ACCADEMY,DARJEELING vs. ITO, WARD 2(2), EXEMP,, SILIGURI

In the result, all the 3 appeals filed by the Assessee are partly

ITA 2748/KOL/2025[2017-2018]Status: DisposedITAT Kolkata26 Feb 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 11Section 12ASection 12A(1)(ac)Section 12A(1)(ba)Section 12A(2)Section 139Section 144Section 2(15)Section 250

…The appellant has not been able to establish its claim that the activity of running the school is not in the nature of profiteering. In this regard, reliance is placed on the decision of the Hon'ble Supreme Court in Sole Trustee, Loka Shikshana Trust v. CIT [101 ITR 234 (SC)] wherein it was held that if an institution runs with the primary object of making profit, even though cloaked as "education", it amounts to business. In the present case, the Ld. AO has rightly treated the appellant's income as "business income" since the appellant has neither demonstrated its eligibility to be treated as a charitable insti…

DOLPHIN CLUB,CHENNAI vs. CIT EXEMPTIONS, CHENNAI

The appeal of the assessee is allowed

ITA 3107/CHNY/2024[-]Status: DisposedITAT Chennai23 Feb 2026

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकरअपीलसं. Ita No 3107/Chny/2024 "नधा"रणवष"/Assessment Years: -- Dolphin Club V. Cit, (E), 3/15, Jeswanth Nagar, Mogappiar No. 121, Mahatma Gandhi West,Chennai-600037 Road, Nungambakkam Chennai-600034 [Pan: Aaatd 0288 P] (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Respondent: Mr. Shiva Srinivas, CIT
Section 10Section 12ASection 12A(1)(ac)Section 2(15)

…een provided. Information regarding the determination of the fee structure and whether the fees charged exceed the limits prescribed by the government is also absent. As clarified by the Hon’ble Supreme Court in Sole Trustee, LokaShikshana Trust v. CIT (1975) 101 ITR 234, the term “education” under section 2(15) refers to systematic instruction, schooling, or training imparted to the young to prepare them for life, and includes scholastic instruction received through a structured course of study. The term is not intended to cover every form of knowledge acquisition in its widest sense.If the term “education” IT…

ARTH FOUNDATION,NASHIK vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE, PUNE

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 2258/PUN/2025[2026-27]Status: DisposedITAT Pune29 Jan 2026AY 2026-27

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2258/Pun/2025 निर्धारण वषा / Assessment Year: 2026-27 Arth Foundation, V Commissioner Of Income Flat No.3, Tulip Apartment, S Tax (Exemption), Pune. Suyojit Garden, Gangapur Road, Nashik – 422013. Pan: Aahta2324C Appellant/ Assessee Respondent / Revenue Assessee By Ca Trishala R Jain (Virtual) Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 21/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Passed Under Section 80G Of The Income Tax Act, 1961 Dated 01.08.2025. The Assessee Has Raised The Following Grounds Of Appeal : ―1. The Learned Cit(E), Pune Has Erred In Rejecting The 1 Application Of The Appellant Trust Filed U/S 80G(5)(Iii) Of The Act Without Considering The Merits Of The Case.

Section 80GSection 80G(5)Section 80G(5)(iii)Section 80G(5)(iv)

…that interpretation of a statute being an exercise in the ascertainment of meaning, everything which is logically relevant should be admissible. In fact there are at least three decisions of this Court, one in Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234, the other in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 and the third in Addl. CIT v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR l/[1980] 2 Taxman 501, where the speech made by the Finance Minister, while introducing the exclusionary clause in section 2(15) of the Act, was relied upon by the Court for the purpose of…

MANJREKAR FOUNDATION,PUNE vs. CIT, EXEMPTION, PUNE, PUNE

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 2338/PUN/2025[-]Status: DisposedITAT Pune27 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2338/Pun/2025 निर्धारण वषा / Assessment Year: - Manjrekar Foundation, V Cit Exemption, Near Goodluckchowk, Decan S Pune. Gymkhana, Bhandarkar Road, Deccan Gymkhana, Pune – 411004. Pan: Aactm7144D Appellant/ Assessee Respondent / Revenue Assessee By Smt Deepa Khare Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 22/01/2026 Date Of Pronouncement 27/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Passed Under Section 80G Of The Income Tax Act, 1961 Dated 30.08.2025. The Assessee Has Raised The Following Grounds Of Appeal : ―1. The Ld. Cit Exemption Erred In Law & On Facts In Treating The Application Under Clause (Iii) Of First Proviso To Sub-Section (5) Of Section 80G As Non- Maintainable On The Ground Of Being Filed Beyond The Statutory Period As Provided In Clause (Iii) Of First Proviso To Section 80G (5) & Thereby Rejecting The Same Without Going Into The Merits.

Section 10Section 11Section 3Section 80GSection 80G(5)

…atute being an exercise in the ascertainment of meaning, everything which is logically relevant should be admissible. In 6 fact there are at least three decisions of this Court, one in Sole Trustee, ITA No.2338/PUN/2025 [A] Loka Shikshana Trust v. CIT [1975] 101 ITR 234, the other in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 and the third in Addl. CIT v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR l/[1980] 2 Taxman 501, where the speech made by the Finance Minister, while introducing the exclusionary clause in section 2(15) of the Act, was relied upon by the Court for the purpose of…

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

ITA 1670/CHNY/2024[2018-19]Status: DisposedITAT Chennai21 Jan 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri G. Baskar, Advocate &For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

…activities such as operating a school or college. She submits education under section 2(15) of the Act requires systematic inspection, schooling or training as defined by the Hon’ble Supreme Court in the case of Sole Trustee, Lok Shikshanath Trust reported in 101 ITR 234 (SC) as the process of training and developing the knowledge, skill, mind and character of students by normal schooling. The sale of materials lacks these elements such as curriculum or by oversight educational authorities. The assessee’s arguments that supplying text books contributes to education requiring no physical school is untenable. The 2…

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

ITA 1667/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

…activities such as operating a school or college. She submits education under section 2(15) of the Act requires systematic inspection, schooling or training as defined by the Hon'ble Supreme Court in the case of Sole Trustee, Lok Shikshanath Trust reported in 101 ITR 234 (SC) as the process of training and developing the knowledge, skill, mind and character of students by normal schooling. The sale of materials lacks these elements such as curriculum or by oversight educational authorities. The assessee's arguments that supplying text books contributes to education requiring no physical school is untenable. The s…

NATIONAL INSTITUTE OF CONSTRUCTION MANAGEMENT AND RESEARCH,MUMBAI vs. DCIT(EXEM), CIRCLE - 2, MUMBAI

ITA 4324/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 Jan 2026AY 2022-23

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri Solgy Jose T. Kottaram, CIT-DR
Section 11Section 11(4)Section 12ASection 143(3)Section 2(15)

…means education in its scholastic sense of structured learning rather than the wider meaning of the term. In this regard, the learned CIT(E) placed reliance upon the decision of the Hon'ble Supreme Court in Sole Trustee LokShikshana Trust, reported in (1975) 101 ITR 234 (SC). The learned CIT(E) also placed reliance on the decision of the Hon'ble Supreme Court in M/s. New Noble Educational Society Vs. The Chief Commissioner of Income Tax, in Civil Appeal No. 3795 of 2014, and held that in the aforesaid decision, it has been reaffirmed that the entities claiming exemption on the ground of imparting education have…

IT2B RESEARCH FOUNDATION,GURGAON vs. CIT(E), CHANDIGARH

In the result, Appeal of the Assessee is dismissed

ITA 7766/DEL/2018[-]Status: DisposedITAT Delhi29 Dec 2025

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandrait2B Research Foundation, Cit(Exemptions), 436, Sector-22,Gurgaon- Chandigarh. 122015,Haryana. Vs Pan-Aaec10816K (Appellant) (Respondent) Appellant By None Respondent By Shri Amit Jain, Cit-Dr Date Of Hearing 16.12.2025 Date Of Pronouncement 29 .12.2025 Order Per Yogesh Kumar U.S., Jm: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Exemptions), Chandigarh[“Ld.Cit(E)”, For Short], Dated 28.09.2018 Wherein The Cit(E) Denied The Registration To The Applicant U/S 12Aa Of The Income Tax Act, 1961 (‘The Act’ For Short).

Section 12ASection 2(15)

…ITA No. 7766/Del/2018 IT2B Research vs. CIT(E) IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER IT2B Research Foundation, CIT(Exemptions), 436, Sector-22,Gurgaon- Chandigarh. 122015,Haryana. Vs PAN-AAEC10816K (Appellant) (Respondent) Appellant by None Respondent by Shri Amit Jain, CIT-DR Date of Hearing 16.12.2025 Date of Pronouncement 29 .12.2025 ORDER PER YOGESH KUMAR U.S., JM: This appeal is filed by the Assessee against the order of Learned Commissioner of Income Tax (Exemptions), Chandigarh[“Ld.CIT(E)…

M/S DESHPANDE EDUCATION TRUST vs. THE ASSISTANT COMMISSIONER OF

In the result, the appeal is allowed

ITA/100009/2017HC Karnataka17 Dec 2025

Bench: S G PANDIT,GEETHA K.B.

Section 11Section 12ASection 142(1)Section 143(2)Section 143(3)Section 2(15)Section 260A

…CC (Tax) 14 : (1975) 101 ITR 234] as well as Indian Chamber of Commerce case [(1976) 1 SCC 324 : 1976 SCC (Tax) 41 : (1975) 101 ITR 796] . It was said by Khanna, J. in Sole Trustee, Loka Shikshana Trust case [(1976) 1 SCC 254 : 1976 SCC (Tax) 14 : (1975) 101 ITR 234] : - 16 - ITA No.100009 of 2017 “[I]f the activity of a trust consists of carrying on a business and there are no restrictions on its making profit, the court would be well justified in assuming in the absence of some indication to the contrary that the object of the trust involves the carrying on of an activity for p…

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

…to equate with imparting education means the formally seeking with teacher and taught implying that the activities are the formal education. The Ld.AR on the other hand, relied on the order of Sole Trustee Loka Shikshana Trust vs Respondent reported in [1975] 101 ITR 234 (SC) which is formed by the order of New Noble Education Society (supra) and defines ‘education’ as systematic instruction, training and development to knowledge and school. The relevant observation of Hon’ble Apex Court in New Noble Education Society (supra) is reproduced as follows:- “33. The subject of education is vast, even sublime. Yet, it…

ACIT, EXEMPTIONS, CIRCLE-1, AHMEDABAD, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1656/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad02 Dec 2025AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 10(23)(iiiad)Section 11Section 11(1)(a)Section 11(1)(d)Section 11(2)Section 143(3)Section 2(15)

…viding "imparting education" the Hon 'ble Tribunal, Delhi Benches in the matter of Divya Yog Mandir Trust-vs-JCIT, Hardwar relied upon the observation made by the Hon'ble Apex Court in the matter of Sole Trustee, Lok Shikshana Trust-vs-CIT, reported in [1975] 101 ITR 234 wherein in the context of section 2(15) of the Act, education has been explained as a process of training and developing the knowledge, skill, mind and character of students by schooling by way of systematic instruction, schooling or training. Therefore, any form of education activity involving imparting of systematic training in order to develop…

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