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

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

…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…

The Assocation of Colon and Rectal Surgeons of India, Jalandhar vs. CIT Exemptions, Chandigarh

In the result, both the appeals are dismissed

ITA 475/ASR/2024[NA]Status: DisposedITAT Amritsar09 Jun 2025

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 474 & 475/Asr/2024 The Association Of Colon & बनाम The Cit Rectal Surgeons Of India, Exemption, 408A, Kapurthala Road, Chandigarh Adarsh Nagar, Jalandhar स्थायी लेखा सं./Pan No: Aakat9866E अपीलाथी/Appellant प्रत्यथी/Respondent ( Hybrid Hearing ) निर्ााररती की ओर से/Assessee By : Sh. Sushil Sharma, Advocate राजस्व की ओर से/ Revenue By : Smt. Vandana Vijay Mohite, Cit Dr सुिवाई की तारीख/Date Of Hearing : 20.03.2025 उदघोषणा की तारीख/Date Of Pronouncement : 09.06.2025 आदेश/Order Per Krinwant Sahay, Am: Appeals In These Cases Have Been Filed By The Assessee Against The Separate Orders, Each Dated 21.03.2024, Passed By Ld. Commissioner Of Income Tax, Exemptions, Chandigarh.

For Appellant: Sh. Sushil Sharma, AdvocateFor Respondent: Smt. Vandana Vijay Mohite, CIT DR

…formal schooling. All other forms of dissemination of knowledge are excluded from the definition of 'education'. The interpretation of the word 'education' was made conservatively by Supreme Court in the case of Sole Trustee, Loka Sikshana Trust v CIT [1975] 101 ITR 234, where it was held that "the word 'education' in section 2(15) has been used to denote systematic instruction, schooling or training given to the young in preparation for the work of life and it also connotes the whole course of scholastic instruction which a person has received, which led to the understanding that only institutions affiliated to…

The Association of Colon and Rectal Surgeons of India, Jalandhar vs. CIT Exemption, Chandigarh

In the result, both the appeals are dismissed

ITA 474/ASR/2024[NA]Status: DisposedITAT Amritsar09 Jun 2025

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 474 & 475/Asr/2024 The Association Of Colon & बनाम The Cit Rectal Surgeons Of India, Exemption, 408A, Kapurthala Road, Chandigarh Adarsh Nagar, Jalandhar स्थायी लेखा सं./Pan No: Aakat9866E अपीलाथी/Appellant प्रत्यथी/Respondent ( Hybrid Hearing ) निर्ााररती की ओर से/Assessee By : Sh. Sushil Sharma, Advocate राजस्व की ओर से/ Revenue By : Smt. Vandana Vijay Mohite, Cit Dr सुिवाई की तारीख/Date Of Hearing : 20.03.2025 उदघोषणा की तारीख/Date Of Pronouncement : 09.06.2025 आदेश/Order Per Krinwant Sahay, Am: Appeals In These Cases Have Been Filed By The Assessee Against The Separate Orders, Each Dated 21.03.2024, Passed By Ld. Commissioner Of Income Tax, Exemptions, Chandigarh.

For Appellant: Sh. Sushil Sharma, AdvocateFor Respondent: Smt. Vandana Vijay Mohite, CIT DR

…formal schooling. All other forms of dissemination of knowledge are excluded from the definition of 'education'. The interpretation of the word 'education' was made conservatively by Supreme Court in the case of Sole Trustee, Loka Sikshana Trust v CIT [1975] 101 ITR 234, where it was held that "the word 'education' in section 2(15) has been used to denote systematic instruction, schooling or training given to the young in preparation for the work of life and it also connotes the whole course of scholastic instruction which a person has received, which led to the understanding that only institutions affiliated to…

Kalasadhanalaya, Chennai vs. Commissioner of Income Tax (Exemptions), Chennai

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

ITA 3056/CHNY/2024[2025-26]Status: DisposedITAT Chennai28 Apr 2025AY 2025-26

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 3056/Chny2024 िनधा"रण वष" / Assessment Year: 2025-26 Kalasadhanalaya, Commissioner Of Income Tax 80A/2, Sriram Apartments, Vs. (Exemptions), St.Marys Road, 121, Mahatma Gandhi Road, Abhiramapuram – 600 018. Nungambakkam, Chennai – 600 018. [Pan: Aaatk-8213-F ] (""यथ"/Respondent) (अपीलाथ"/Appellant)

For Appellant: Shri. S.Vignesh, C.AFor Respondent: Shri. M.Murali, C.I.T
Section 12ASection 2(15)Section 80G

…आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी एबी टी वक", "ाियक सद" एवं "ी एस. आर. रघुनाथा, लेखा सद"य के सम" BEFORE SHRI ABY T VARKEY, HON’BLE JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, HON’BLE ACCOUNTANT MEMBER आयकर अपील सं./ITA No.: 3056/Chny2024 िनधा"रण वष" / Assessment Year: 2025-26 Kalasadhanalaya, Commissioner of Income Tax 80A/2, Sriram Apartments, vs. (Exemptions), St.Marys Road, 121, Mahatma Gandhi Road, Abhiramapuram – 600 018. Nungambakkam, Chennai – 600 018. [PAN: AAATK-8213-F ] (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant by :…

Mitcon Forum for Social Development, Pune vs. CIT Exemption, Pune

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

ITA 613/PUN/2025[2024-25]Status: DisposedITAT Pune24 Apr 2025AY 2024-25

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.613/Pun/2025 िनधा"रण वष" / Assessment Year: 2024-25 Mitcon Forum For Social V The Commissioner Of Development, S Income Tax(Exemption), Kebera Chambers, 1St Floor, Pune. Shivajinagar, Pune – 411005. Maharashtra Pan: Aalcm9558M Appellant/ Assessee Respondent / Revenue Assessee By Shri Sharad A Vaze – Ar Revenue By Shri Ramnath P Murkude – Cit-Dr Date Of Hearing 22/04/2025 Date Of Pronouncement 24/04/2025 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, Pune Passed Under Section 80G(5) Of The Income Tax Act, 1961; Dated 19.02.2025. 2. The Assessee Has Raised The Following Ground Of Appeal : “1. On The Basis Of Facts & In The Circumstances Of The Case & As Per Law, The Commissioner Of Income Tax,(Exemptions) Pune, Is Not

Section 10Section 11Section 12ASection 13(1)Section 80GSection 80G(5)Section 80G(5)(iii)

…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 ITA No.613/PUN/2025 [A] the Act, was relied upon by the…

Shree Vishwakarma Sutradhar Sampati Trust, Bikaner vs. Income Tax Officer, Exemption, Bikaner

In the result, appeal of the assessee is partly allowed in above terms

ITA 305/JODH/2024[2017-2018]Status: DisposedITAT Jodhpur28 Mar 2025AY 2017-2018

Bench: Hearing On The Case.

For Appellant: Shri Amit Kothari (CA)For Respondent: Shri Karni Dan, Addl. CIT
Section 11Section 11(1)(a)Section 12ASection 143(2)Section 250

…cided the case in arbitrary manner. For the purpose of benefit of section of public is also treated as good as public at large. We can take the support of 7 Shree Vishwakarma Sutradhar Sampati Trust, Bikaner. decisions of Hon’ble SC reported in 82 ITR 704 and 101 ITR 234. Sir, for wrong interpretation made by the Assessing Officer as well as by CIT (Appeal) when trust has been formed for the benefit of public at large and both the authorities either confused with the word or arbitrarily interpreted have decided the case dehors the objectives sought to be achieved for public at large. The word cannot be dubbed as…

Maqbool Hussain Educational Welfare Society, Visakhapatnam vs. Income Tax Officer (Exemption Ward), Visakhapatnam

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

ITA 449/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam05 Mar 2025AY 2018-19

Bench: Shri K.Narasimha Chary & Shri Balakrishnan S.

For Appellant: Shri P.Murali Mohanarao, ARFor Respondent: Dr.Satyasai Rath, CIT-DR
Section 10

…confirmed the findings of the learned Assessing Officer. Hence this appeal. 5. It is the argument of the learned AR that though the learned Assessing Officer referred to the decision of the Hon’ble Apex Court in the case of Sole Trustee, Loka Shikshana Trust 101 ITR 234 (SC), he failed to apply the same appropriately to the facts of the case. He placed reliance on the decision of the coordinate bench in the case of Assistant Director of Income Tax vs. Hyderabad Study Circle in ITA no. 1645/Hyd/2013 wherein coordinate Bench noticed the decision of Loka Sikshana Trust and held that if an educational institution co…

Maqbool Hussain Educational Welfare Society, Visakhapatnam vs. Income Tax Officer (Exemption Ward), Visakhapatnam

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

ITA 448/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam05 Mar 2025AY 2017-18

Bench: Shri K.Narasimha Chary & Shri Balakrishnan S.

For Appellant: Shri P.Murali Mohanarao, ARFor Respondent: Dr.Satyasai Rath, CIT-DR
Section 10

…confirmed the findings of the learned Assessing Officer. Hence this appeal. 5. It is the argument of the learned AR that though the learned Assessing Officer referred to the decision of the Hon’ble Apex Court in the case of Sole Trustee, Loka Shikshana Trust 101 ITR 234 (SC), he failed to apply the same appropriately to the facts of the case. He placed reliance on the decision of the coordinate bench in the case of Assistant Director of Income Tax vs. Hyderabad Study Circle in ITA no. 1645/Hyd/2013 wherein coordinate Bench noticed the decision of Loka Sikshana Trust and held that if an educational institution co…

Maqbool Hussain Educational Welfare Society, Visakhapatnam vs. Income Tax Officer (Exemption Ward), Visakhapatnam

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

ITA 447/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam05 Mar 2025AY 2016-17

Bench: Shri K.Narasimha Chary & Shri Balakrishnan S.

For Appellant: Shri P.Murali Mohanarao, ARFor Respondent: Dr.Satyasai Rath, CIT-DR
Section 10

…confirmed the findings of the learned Assessing Officer. Hence this appeal. 5. It is the argument of the learned AR that though the learned Assessing Officer referred to the decision of the Hon’ble Apex Court in the case of Sole Trustee, Loka Shikshana Trust 101 ITR 234 (SC), he failed to apply the same appropriately to the facts of the case. He placed reliance on the decision of the coordinate bench in the case of Assistant Director of Income Tax vs. Hyderabad Study Circle in ITA no. 1645/Hyd/2013 wherein coordinate Bench noticed the decision of Loka Sikshana Trust and held that if an educational institution co…

Maqbool Hussain Educational Welfare Society, Visakhapatnam vs. Income Tax Officer (Exemption Ward), Visakhapatnam

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

ITA 446/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam05 Mar 2025AY 2015-16

Bench: Shri K.Narasimha Chary & Shri Balakrishnan S.

For Appellant: Shri P.Murali Mohanarao, ARFor Respondent: Dr.Satyasai Rath, CIT-DR
Section 10

…confirmed the findings of the learned Assessing Officer. Hence this appeal. 5. It is the argument of the learned AR that though the learned Assessing Officer referred to the decision of the Hon’ble Apex Court in the case of Sole Trustee, Loka Shikshana Trust 101 ITR 234 (SC), he failed to apply the same appropriately to the facts of the case. He placed reliance on the decision of the coordinate bench in the case of Assistant Director of Income Tax vs. Hyderabad Study Circle in ITA no. 1645/Hyd/2013 wherein coordinate Bench noticed the decision of Loka Sikshana Trust and held that if an educational institution co…

Bisa Neema Panchayat Bhawan Trust, M.G Road vs. Commissioner of Income Tax (Exemption) Bhopal

Appeal is allowed for statistical purpose

ITA 480/IND/2024[2023-24]Status: DisposedITAT Indore29 Nov 2024AY 2023-24

Bench: Shri B.M. Biyani & Shri Dinesh Mohan Sinhaa.Y. : 2023-24 Bisa Neema Panchayat Commissioner Of Income- Bhawan Trust, Tax (Exemption), बनाम/ 285, M.G. Road, Bhopal Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aactb4287E Assessee By Shri S.S.Deshpande, C.A. & Ar Revenue By Shri V.K. Singh, Cit-Dr Date Of Hearing 27.11.2024 Date Of Pronouncement 29.11.2024

Section 12ASection 13(1)(b)Section 253(5)

…eds to be examined whether such religious-charitable activity carried on by the trust only benefits a certain particular religious community or class or serves across the communities and for society at large. (Sole Trustee, Loka Shikshana Trust v. CIT, (1975) 101 ITR 234 (SC)). The section of community sought to be benefited must be either sufficiently defined or identifiable by a common quality of a public or impersonal nature. (CIT v. Andhra Chamber of Commerce, 55 ITR 722).” [Emphasis supplied] Therefore, the contention of Ld. AR that the section 13(1)(b) is per se not applicable to assessee, being a ‘charit…

ITO(Exmp)-2(4), Mumbai vs. Mehli Mehta Music Foundation, Mumbai

In the result the appeal filed by the revenue stands dismissed

ITA 4545/MUM/2023[2018-19]Status: DisposedITAT Mumbai22 Nov 2024AY 2018-19

Bench: Smt Beena Pillai & Shri Prabhash Shankar[Assessment Year: 2018-19] Income Tax Officer, Mehli Mehta Music Exemption Ward- 2(4) Foundation 609, 6Th Floor, 2, Banoo Mansion, Mtnl Building, Cumballa Hill Road, Vs. Cumballa Hill, Kemps Corner, Mumbai- 400026. Mumbai- 400026. Pan: Aaatt2799K (Appellant) (Respondent)

For Appellant: Shri P. J. Pardiwala & Mayank ThosarFor Respondent: Shri R. R. Makwana (SR. D.R.)
Section 11Section 11(1)(d)Section 2Section 2(15)

…ing of the term as scholastic structured learning is what is meant in Article 21-A, Articles 29-30 and Articles 45-46 of the Constitution. As to what is 'education' in the context of the IT Act, was explained in Sole Trustee, LokaShikshana Trust v. CIT (1975) 101 ITR 234 (SC)/[1976] 1 SCC 254 in the following terms: "5. The sense in which the word "education" has been used in section 2(15) is the instruction, schooling or training given to the young in preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received. The word "education" has not been used i…

St. Joseph'S Education and Medical Relief Society, Mumbai vs. Asstt. Director of Income Tax -(E)-II(1), Mumbai

ITA 2509/MUM/2024[2010-11]Status: DisposedITAT Mumbai30 Oct 2024AY 2010-11

Bench: Smt Beena Pillai & Smt Renu Jauhri

Section 12ASection 80G

…g of marriage Hall and ground, Royalties from caterers, Agency commission and Rental income are derived from appellant society. In this regard reliance is placed on the decision of Hon'ble Supreme Court in the case of Sole Trustee, Lok Shikshan Trust vs. CIT (101 ITR 234), even though it is incidental to its main activity of providing business education. Since it is a organized systematic activity, it can be called business incidental to the main object of the society. The hall and ground are given to public on rental basis for marriage and other purposes. The appellant has also received royalty income from cater…

City As Lab Foundation, Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

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

ITA 2025/MUM/2024[2024-25]Status: DisposedITAT Mumbai30 Oct 2024AY 2024-25

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGARWAL (Accountant Member)

Section 124(1)(ac)Section 12ASection 8(1)

…s given the following two reasons to reject the registration of the assessee: a. The assessee is not affiliated to any board or university and is not providing formal education as held by the Apex Court in the case of Sole Trustee, Lok Shikshana Trust vs CIT (101 ITR 234). b. The assessee is providing education for a fee and with a profit motive. 7. Before us ld. Counsel submitted that assessee may not be affiliated to any Board or University however, it was carrying out the activities in the field of education only. He has given the following activities and objects which were carried out by the assessee; a. The…

City As Lab Fondation, Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

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

ITA 2023/MUM/2024[2024-25]Status: DisposedITAT Mumbai30 Oct 2024AY 2024-25

Bench: SHRI AMIT SHUKLA (Judicial Member)

Section 124(1)(ac)Section 12ASection 8(1)

…s given the following two reasons to reject the registration of the assessee: a. The assessee is not affiliated to any board or university and is not providing formal education as held by the Apex Court in the case of Sole Trustee, Lok Shikshana Trust vs CIT (101 ITR 234). b. The assessee is providing education for a fee and with a profit motive. 7. Before us ld. Counsel submitted that assessee may not be affiliated to any Board or University however, it was carrying out the activities in the field of education only. He has given the following activities and objects which were carried out by the assessee; a. The…

The Institute of Indian Foundrymen, Kolkata vs. I.T.O., Ward - 1(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1123/KOL/2024[2018-2019]Status: DisposedITAT Kolkata15 Oct 2024AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 11Section 143(3)Section 2(15)Section 263

…(A) in their orders relied upon the following judicial decisions: * Barendra Prasad Ray v. Income-tax Officer (129 ITR 295) SC * Commissioner of Income-tax v. Dharma Reddy (A) (73 ITR 751) SC * Sole Trustee, LokaShikshana Trust v. Commissioner of Income-tax (101 ITR 234 SC) We have already discussed the case law of Hon'ble Delhi High Court in the case of PHD Chamber of Commerce &Industry(Supra), wherein very categorically held that activities and services performed for a fee or against a payment, by a trade, professional or similar association, such as a chamber of commerce and industry could not be held to be “…

Sanatana Dharma Vidyasala, Alappuzha vs. The Commissioner of Income Tax (Exemption), Kochi

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

ITA 279/COCH/2024[2024-25]Status: DisposedITAT Cochin25 Sept 2024AY 2024-25

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: Shri Dr. S. Pandian, CIT-DR
Section 12A(1)(ac)Section 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…

Sanatana Dharma Educational and Cultural Society, Alappuzha vs. The Commissioner of Income Tax (Exemption), Kochi

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

ITA 278/COCH/2024[2024-25]Status: DisposedITAT Cochin25 Sept 2024AY 2024-25

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: Shri Dr. S. Pandian, CIT-DR
Section 12A(1)(ac)Section 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…

Aadhar Shikshan Sanstha Yelavi, Sangli vs. CIT, Exemption, Pune

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

ITA 748/PUN/2024[-]Status: DisposedITAT Pune12 Sept 2024

Bench: Ms.Astha Chandra & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.748/Pun/2024 िनधा"रण वष" / Assessment Year : N.A. Aadhar Shikshan Sanstha The Commissioner Of Yelavi, V Income Tax, Exemption, At Post Yelavi, Tal Tasgaon, S Pune. Dist. Sangli, Sangli – 416416. Pan: Aaata3972D Appellant/ Assessee Respondent /Revenue Assessee By Smt. Deepa Khare – Ar Revenue By Shri Mirtyunjoy Barnwal – Dr Date Of Hearing 11/09/2024 Date Of Pronouncement 12/09/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is Assessee’S Appeal Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Under Section 80G Of The Act, Dated 15.02.2024. The Ld.Cit(E) Dismissed The Application Of The Assessee On The Ground That The Application Is Time Barred. The Assessee Has Raised The Following Ground(S) Of Appeal : “1. The Id Cit Exemption Erred In Law & On Facts In Treating The Application Under Clause (Iit) Of First Proviso To Sub-Section (5) Of Section 80G As Non- Maintainable On The Ground Of Being Filed Aadhar Shikshan Sanstha Yelavi [A]

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

…।आयकर अपीलीय अिधकरण ”ए” "ायपीठ पुणेम"। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A” :: PUNE BEFORE MS.ASTHA CHANDRA, JUDICIAL MEMBER AND DR. DIPAK P. RIPOTE, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No.748/PUN/2024 िनधा"रण वष" / Assessment Year : N.A. Aadhar Shikshan Sanstha The Commissioner of Yelavi, V Income Tax, Exemption, At Post Yelavi, Tal Tasgaon, s Pune. Dist. Sangli, Sangli – 416416. PAN: AAATA3972D Appellant/ Assessee Respondent /Revenue Assessee by Smt. Deepa Khare – AR Revenue by Shri Mirtyunjoy Barnwal – DR Date of hearing 11/09/2024 Date of pronouncement 12/09/2024 आदेश/ ORDER PER DR. DIPAK P…

Shree Rajput Sabha, Jaipur vs. CIT(Exemption), Jaipur

ITA 311/JPR/2020[2019-20]Status: DisposedITAT Jaipur10 Sept 2024AY 2019-20
For Appellant: Shri Tarun Mittal (C.A.)For Respondent: Shri Arvind Kumar (CIT)
Section 11Section 12ASection 2(15)Section 80GSection 80G(5)(vi)

…run on commercial lines and also do not qualify as "education" as contemplated under the head "education" in Sec. 2(15), which defines charitable purpose. To drive home Hon'ble Supreme Court's in the case of in Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC), all kinds of acquiring knowledge will not come within the meaning of "education as appearing in Sec. 2(15). What "education" Connotes is systematic instruction by way of normal schooling. Therefore, he held that there should be a systematic instruction to the students by way of normal schooling. Mere training activities may provide some kin…