Sole Trustee, Loka Shikshana Trust v. CIT

101 ITR 234Supreme Court of India1975#239 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 366,005 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
Read the full judgment

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

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

…for shorter period cannot be the reason to hold that the assessee is not engaged in imparting education. The ld. AR drew our attention to the following observations of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT [1975] 101 ITR 234 (SC) where the term "education" is explained by the Apex Court "The sense in which the word "education" has been used in section 2(15) in the systematic instruction, schooling or training given to the young is preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "educa…

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

…for shorter period cannot be the reason to hold that the assessee is not engaged in imparting education. The ld. AR drew our attention to the following observations of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT [1975] 101 ITR 234 (SC) where the term "education" is explained by the Apex Court "The sense in which the word "education" has been used in section 2(15) in the systematic instruction, schooling or training given to the young is preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "educa…

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

…for shorter period cannot be the reason to hold that the assessee is not engaged in imparting education. The ld. AR drew our attention to the following observations of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT [1975] 101 ITR 234 (SC) where the term "education" is explained by the Apex Court "The sense in which the word "education" has been used in section 2(15) in the systematic instruction, schooling or training given to the young is preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "educa…

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

…for shorter period cannot be the reason to hold that the assessee is not engaged in imparting education. The ld. AR drew our attention to the following observations of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT [1975] 101 ITR 234 (SC) where the term "education" is explained by the Apex Court "The sense in which the word "education" has been used in section 2(15) in the systematic instruction, schooling or training given to the young is preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "educa…

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

…for shorter period cannot be the reason to hold that the assessee is not engaged in imparting education. The ld. AR drew our attention to the following observations of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT [1975] 101 ITR 234 (SC) where the term "education" is explained by the Apex Court "The sense in which the word "education" has been used in section 2(15) in the systematic instruction, schooling or training given to the young is preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "educa…

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

…for shorter period cannot be the reason to hold that the assessee is not engaged in imparting education. The ld. AR drew our attention to the following observations of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT [1975] 101 ITR 234 (SC) where the term "education" is explained by the Apex Court "The sense in which the word "education" has been used in section 2(15) in the systematic instruction, schooling or training given to the young is preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "educa…

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

…for shorter period cannot be the reason to hold that the assessee is not engaged in imparting education. The ld. AR drew our attention to the following observations of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT [1975] 101 ITR 234 (SC) where the term "education" is explained by the Apex Court "The sense in which the word "education" has been used in section 2(15) in the systematic instruction, schooling or training given to the young is preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "educa…

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

…for shorter period cannot be the reason to hold that the assessee is not engaged in imparting education. The ld. AR drew our attention to the following observations of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT [1975] 101 ITR 234 (SC) where the term "education" is explained by the Apex Court "The sense in which the word "education" has been used in section 2(15) in the systematic instruction, schooling or training given to the young is preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "educa…

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

…he assessee are not relevant on the above facts. In fact, the word 'education’ has been defined by various Hon'ble High Courts, I rely on the following judgments of the court. :-5-: ITA. No:1480 /Chny/2025 (a) Sole Trustee. LokShikshana Trust Vs CIT (1975) 101 ITR 234 where the assessee trust was running newspaper and journals in Kannada language. The object of the Trust included educating the people through establishing and helping institutions. Practically printing of newspaper was the activity of the Trust. The Supreme Court Observed, "The sense in which the word "education” has been used in section 2(15) i…

Thavam Research Foundation, Pudukkottai vs. CIT, Exemption, Chennai

ITA 1159/CHNY/2025[-]Status: DisposedITAT Chennai21 Oct 2025

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1159/Chny/2025

Section 12A(1)(ac)

…s of the trust were not in the category of any 'education' as the assessee did not have any valid approval from any recognized body to conduct any educational course. Consequently, relying upon decision of Hon'ble Apex Court in the case of Lokashikashan Trust 101 ITR 234 he rejected the application of assessee for grant of registration. 5.0 The Ld. Counsel for the assessee vehemently argued against the decision of the Ld.CIT(E). It has been submitted that the assessee has been carrying out charitable activities of providing relief to the poor and that it has been regularly conducting workshops and programmes teac…

The Institute of Chartered Shipbrokers, Chennai vs. ITO, Exemptions Ward-2, Chennai

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1931/CHNY/2025[2013-14]Status: DisposedITAT Chennai29 Sept 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…A is granted only for institutions carrying on charitable activities within the territories of India. 6. In support of his arguments the learned Commissioner of Income-tax has relied on the following decisions:- 1. Sole Trustee, Loka Shikshana Trust vs CIT, 101 ITR 234(S.C) 2. Indian Chamber of Commerce vs. CIT, 101 ITR 796 (S.C.) 3. Rajah Sir Annamalai Chettiar Foundation vs. Director of IT(Exemptions), 10 ITR (Trib) 424(Chennai). ITA Nos.1927 to 1931/Chny/2025 The Institute of Chartered Shipbrokers :- 11 -: 4. Bihar Institute of Mining and Mine Surveying vs. CIT, 208 ITR 608 (Patna). 5. CIT vs. National…

The Institute of Chartered Shipbrokers, Chennai vs. ITO, Exemptions Ward-2, Chennai

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1930/CHNY/2025[2012-13]Status: DisposedITAT Chennai29 Sept 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…A is granted only for institutions carrying on charitable activities within the territories of India. 6. In support of his arguments the learned Commissioner of Income-tax has relied on the following decisions:- 1. Sole Trustee, Loka Shikshana Trust vs CIT, 101 ITR 234(S.C) 2. Indian Chamber of Commerce vs. CIT, 101 ITR 796 (S.C.) 3. Rajah Sir Annamalai Chettiar Foundation vs. Director of IT(Exemptions), 10 ITR (Trib) 424(Chennai). ITA Nos.1927 to 1931/Chny/2025 The Institute of Chartered Shipbrokers :- 11 -: 4. Bihar Institute of Mining and Mine Surveying vs. CIT, 208 ITR 608 (Patna). 5. CIT vs. National…

The Insitute of Chartered Shipbrokers, Chennai vs. ITO, Exemptions Ward-2, Chennai

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1929/CHNY/2025[2010-11]Status: DisposedITAT Chennai29 Sept 2025AY 2010-11

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…A is granted only for institutions carrying on charitable activities within the territories of India. 6. In support of his arguments the learned Commissioner of Income-tax has relied on the following decisions:- 1. Sole Trustee, Loka Shikshana Trust vs CIT, 101 ITR 234(S.C) 2. Indian Chamber of Commerce vs. CIT, 101 ITR 796 (S.C.) 3. Rajah Sir Annamalai Chettiar Foundation vs. Director of IT(Exemptions), 10 ITR (Trib) 424(Chennai). ITA Nos.1927 to 1931/Chny/2025 The Institute of Chartered Shipbrokers :- 11 -: 4. Bihar Institute of Mining and Mine Surveying vs. CIT, 208 ITR 608 (Patna). 5. CIT vs. National…

M/S. the Institute of Chartered Shipbrokers, Chennai vs. ITO, Exemptions Ward-3, Chennai

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1928/CHNY/2025[2008-09]Status: DisposedITAT Chennai29 Sept 2025AY 2008-09

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…A is granted only for institutions carrying on charitable activities within the territories of India. 6. In support of his arguments the learned Commissioner of Income-tax has relied on the following decisions:- 1. Sole Trustee, Loka Shikshana Trust vs CIT, 101 ITR 234(S.C) 2. Indian Chamber of Commerce vs. CIT, 101 ITR 796 (S.C.) 3. Rajah Sir Annamalai Chettiar Foundation vs. Director of IT(Exemptions), 10 ITR (Trib) 424(Chennai). ITA Nos.1927 to 1931/Chny/2025 The Institute of Chartered Shipbrokers :- 11 -: 4. Bihar Institute of Mining and Mine Surveying vs. CIT, 208 ITR 608 (Patna). 5. CIT vs. National…

M/S. the Institute of Chartered Shipbrokers, Chennai vs. ITO, Exmeptions Ward-1, Chennai

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1927/CHNY/2025[2007-08]Status: DisposedITAT Chennai29 Sept 2025AY 2007-08

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…A is granted only for institutions carrying on charitable activities within the territories of India. 6. In support of his arguments the learned Commissioner of Income-tax has relied on the following decisions:- 1. Sole Trustee, Loka Shikshana Trust vs CIT, 101 ITR 234(S.C) 2. Indian Chamber of Commerce vs. CIT, 101 ITR 796 (S.C.) 3. Rajah Sir Annamalai Chettiar Foundation vs. Director of IT(Exemptions), 10 ITR (Trib) 424(Chennai). ITA Nos.1927 to 1931/Chny/2025 The Institute of Chartered Shipbrokers :- 11 -: 4. Bihar Institute of Mining and Mine Surveying vs. CIT, 208 ITR 608 (Patna). 5. CIT vs. National…

Aditya Birla Education Trust, Mumbai vs. Commissioner of Income Tax (Exemption), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4474/MUM/2025[NA]Status: DisposedITAT Mumbai19 Sept 2025

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Saurabh Soparkar (virtually appear), Shri Yogesh Thar, ShriFor Respondent: Shri Rajesh Kumar Yadav (CIT-DR)
Section 11Section 12ASection 12A(1)(ac)Section 13(1)(b)

…r other 27 Aditya Birla Education Trust institutions and development programs for the benefit of companies cannot be categorized as Education in Scholastic sense. In fact, the Hon'ble Supreme Court in the case of Sole Trustee Lok Shikshana Trust, reported in 101 ITR 234 has clearly laid down that the scope of education within the meaning of section 2(15) is confined to formal education only, and does not extend to any wider connotation. The relevant findings of Hon'ble Supreme Court are as under The word "education" has not been used in that wide and extended sense, according to which every acquisition of furthe…

Icg-Iisu Alumnae Association-Bandhan, Jaipur vs. CIT (Exemption), Jaipur

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

ITA 923/JPR/2024[NA]Status: DisposedITAT Jaipur11 Sept 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri Ajey Malik, CIT-DR (Thru:V.C.)
Section 12ASection 13(1)Section 254

…rcial basis however, not clanfyin deed that same would be done at free of costat margin. Further the decision of Hon'ble Apex court in case of Ahmedabad Urban Development Authority AUDA, supra has confirmed its position in Sole Trustee Loka Shikshana Sanshtan 101 ITR 234 that position of not meant for profit can be established only if mentioned in deed that assessee would conduct such activities on cost or nominal margin, as assessee failed to include such point in deed, same cannot be considered charitable. Assessee submitted in reply, that by any stretch of imagination library reading room's facilities are not…

National Association for the Blind, Mumbai vs. CIT (Exemptions), Mumbai

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

ITA 2490/MUM/2025[2026-27]Status: DisposedITAT Mumbai29 Aug 2025AY 2026-27

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2026-27

For Appellant: Ms. Jasmin Amalsadvala, Ld. A.RFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. D.R
Section 11Section 80GSection 80G(5)

…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…

Nritya Samsrti, Chennai vs. Income Tax Officer, Chennai

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

ITA 1064/CHNY/2025[NA]Status: DisposedITAT Chennai23 Jul 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.1064/Chny/2025 ननिाारण वर्ा/Assessment Year: Na V. Nritya Samsrti, Commissioner Of Income No.68/160, Big Street, Tax(Exemption), Triplicane, Chennai Chennai-600 005. [Pan: Aadtn4295P] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : अपीलार्थी की ओर से/ Appellant By Mr.Ashwini Vaidialingam प्रत्यर्थी की ओर से /Respondent By : Mr. Bipin C.N, Cit सुनवाईकीतारीख/Date Of Hearing : 21.07.2025 : घोर्णाकीतारीख /Date Of Pronouncement 23.07.2025

For Respondent: Mr. Bipin C.N, CIT
Section 2(15)

…re have consistently been upheld. 5. The Ld. CIT (Exemption) has erred in holding that teaching art forms cannot be considered as education under 5. 2(15). As per the decision of the Hon'ble Supreme Court in Sole Trustee, Loka Shikshana Trust vs. CIT, Mysore, 101 ITR 234, there must be a process of training and developing the knowledge, skill, mind, character of the students by normal schooling, for an activity to fall under the ambit of education. This position of law has been interpreted by various High Courts in the context of trusts teaching music and arts, and have held that the same would be considered educ…

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

…ligible the exemption u/s 11 of the Act. Vide paragraph Nos. 20 to 28 of the order in Nos. 20 to 28 of the order in assessee's own case for the assessment years 2006-07 to 2009-10 the Hon'ble High Court, while referring to 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), C…