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 366,314 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

The Institute of Indian Foundrymen, Kolkata vs. ITO, Ward-1(3), Exempt, Kolkata.

In the result, the appeal of the assessee is allowed

ITA 906/KOL/2023[2014-15]Status: DisposedITAT Kolkata18 Mar 2024AY 2014-15

Bench: Shri Sanjay Garg & Shri Rajesh Kumar]

Section 11Section 12ASection 2(15)

…(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 “…

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)

…integra in the light of settled legal position laid in ‘Sinhagad Technical Education Society Vs CIT Central & Ors.’ reported as 343 ITR 23(Bom), ‘Delhi Stock Exchange Association Ltd. Vs CIT’, reported in 225 ITR 235 (SC), ‘Indian Chamber of Commerce Vs CIT’, 101 ITR 796 (SC); ‘Ideal Publications Trust Vs CIT’, 305 ITR 143 (Kerala); ‘CIT Vs National Institute of Aeronautical Engineering Educational Society’, 315 ITR 428 (Uttarakhand); wherein it has been held that, the registering authority who is empowered to grant registration had inherent powers for cancelling it even before it has been specifically conferred…

Patheya Kan Sansthan, Jaipur vs. Assistant Commissioner of Income Tax, Circle-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 583/JPR/2019[2010-11]Status: DisposedITAT Jaipur13 Feb 2024AY 2010-11

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

For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri Anoop Singh,Addl.CIT
Section 11Section 12ASection 143(2)Section 143(3)Section 2Section 2(15)

…आयकरअपीलीय अधिकरण] जयपुरन्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, ‘’B” JAIPUR Mk0 ,l- lhrky{eh]U;kf;dlnL; ,oaJhjkBksMdeys'kt;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihy la-@ITA No. 583/JP/2019 fu/kZkj.ko"kZ@AssessmentYear : 2010-11 cuke Patheya Kan Sansthan The ACIT B-19,New Colony, Bharati Bhawan Vs. Circle-1 Jaipur Jaipur LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAATP 2508 C vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@Assessee by : Shri Rajeev Sogani, CA jktLo dh vksj ls@Revenue by: Shri Anoop Singh,A…

Indore Development Authority, Indore vs. The CIT Exemption, Circie, Bhopal

The appeal of the assessee is dismissed

ITA 69/IND/2023[00]Status: DisposedITAT Indore24 Jan 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisection 12Ab Indore Development Cit-(Exemption) Authority, Bhopal Vs. Ida Building, 7, Race Course Road, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaaji 0103 J Assessee By S/Sh. Anil Kamal Garg & Arpit Gaur, Cas Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 13.12.2023 Date Of Pronouncement 24.01.2024

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

…le thinking is always directed as benefit to others. It is this direction of thought and efforts and not the result what is done in term of financially measurable gain which determines that it is charitable [quoted from Sole Trustee Lok Shikshan Trust vs. CIT(101 ITR 234) (SC)]. Since the main predominant object of the assessee is profit making, therefore, we find no infirmity in the impugned order in denying registration u/s 12A/12AA of the Act to the assessee. Thus, on this issue, we affirm the stand taken by the ld. first appellate authority.” 7 Indore Development Authority 5. On consideration of above, we fi…

Sri Aurobindo Ashram Trust, Pondicherry vs. DCIT, Exemptions, Chennai

Appeals are allowed for statistical purposes

ITA 147/CHNY/2019[2015-16]Status: DisposedITAT Chennai09 Jan 2024AY 2015-16

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha.G

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. AR.V.Sreenivasan, Addl.CIT
Section 143(3)Section 147Section 148

…s explained the consideration in the said Act, the genuine commercial activities that are incidental and that do not exceed Rs.10 lakh. Consequent to the amendment in section 2(15), earlier landmark decision of apex court in Indian Chamber of Commerce Vs CIT [101 ITR 796) has become significant in the cases like that of the present appellant in favour of revenue. 5.7.l ITAT Mumbai in the case of MIG Cricket Club vs. DIT (E) ITAT Mumbai held on 28/04/2017 that activities of the assessee of Banquet Hall Hiring. Hospitality (Restaurants} and Permit Room (Bar) are in rhe nature of carrying on track, commerce, or busi…

Sri Aurobindo Ashram Trust, Pondicherry vs. DCIT, Exemptions, Chennai

Appeals are allowed for statistical purposes

ITA 146/CHNY/2019[2014-15]Status: DisposedITAT Chennai09 Jan 2024AY 2014-15

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha.G

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. AR.V.Sreenivasan, Addl.CIT
Section 143(3)Section 147Section 148

…s explained the consideration in the said Act, the genuine commercial activities that are incidental and that do not exceed Rs.10 lakh. Consequent to the amendment in section 2(15), earlier landmark decision of apex court in Indian Chamber of Commerce Vs CIT [101 ITR 796) has become significant in the cases like that of the present appellant in favour of revenue. 5.7.l ITAT Mumbai in the case of MIG Cricket Club vs. DIT (E) ITAT Mumbai held on 28/04/2017 that activities of the assessee of Banquet Hall Hiring. Hospitality (Restaurants} and Permit Room (Bar) are in rhe nature of carrying on track, commerce, or busi…

Sri Aurobindo Ashram Trust, Pondicherry vs. DCIT, Exemptions, Chennai

Appeals are allowed for statistical purposes

ITA 145/CHNY/2019[2012-13]Status: DisposedITAT Chennai09 Jan 2024AY 2012-13

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha.G

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. AR.V.Sreenivasan, Addl.CIT
Section 143(3)Section 147Section 148

…s explained the consideration in the said Act, the genuine commercial activities that are incidental and that do not exceed Rs.10 lakh. Consequent to the amendment in section 2(15), earlier landmark decision of apex court in Indian Chamber of Commerce Vs CIT [101 ITR 796) has become significant in the cases like that of the present appellant in favour of revenue. 5.7.l ITAT Mumbai in the case of MIG Cricket Club vs. DIT (E) ITAT Mumbai held on 28/04/2017 that activities of the assessee of Banquet Hall Hiring. Hospitality (Restaurants} and Permit Room (Bar) are in rhe nature of carrying on track, commerce, or busi…

Sri Aurobindo Ashram Trust, Pondicherry vs. DCIT, Exemptions, Chennai

Appeals are allowed for statistical purposes

ITA 144/CHNY/2019[2009-10]Status: DisposedITAT Chennai09 Jan 2024AY 2009-10

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha.G

For Appellant: Mr. S. Sridhar, AdvocateFor Respondent: Mr. AR.V.Sreenivasan, Addl.CIT
Section 143(3)Section 147Section 148

…s explained the consideration in the said Act, the genuine commercial activities that are incidental and that do not exceed Rs.10 lakh. Consequent to the amendment in section 2(15), earlier landmark decision of apex court in Indian Chamber of Commerce Vs CIT [101 ITR 796) has become significant in the cases like that of the present appellant in favour of revenue. 5.7.l ITAT Mumbai in the case of MIG Cricket Club vs. DIT (E) ITAT Mumbai held on 28/04/2017 that activities of the assessee of Banquet Hall Hiring. Hospitality (Restaurants} and Permit Room (Bar) are in rhe nature of carrying on track, commerce, or busi…

T B Lulla Charitable Foundation, Sangli vs. CIT Exemption, Pune

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

ITA 1220/PUN/2023[--]Status: DisposedITAT Pune05 Jan 2024

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.1220/Pun/2023 िनधा"रण वष" / Assessment Year :- T B Lulla Charitable The Cit Exemption, Foundation, V Pune. Atit Bungalow South Shivaji S Nagar, Behind Mali Chitr Mandir, Sangli - 416416. Pan: Aaect9113E Appellant/ Assessee Respondent /Revenue Assessee By Smt. Deepa Khare – Ar Revenue By Shri Rakesh Jha – Cit(Dr) Date Of Hearing 19/12/2023 Date Of Pronouncement 05/01/2024

Section 10Section 11Section 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…

Shri Kailash Math Trust, Nashik vs. The Commissioner of Income Tax (Exemption), Pune

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

ITA 1177/PUN/2023[-]Status: DisposedITAT Pune05 Jan 2024

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.1177/Pun/2023 िनधा"रण वष" / Assessment Year : N.A. Shri Kailash Math Trust, The Cit(Exemption), Bhaktidhan, Panchavati Peth V Pune. Road, Nashik – 422003. S Pan: Aabas0761Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Kishor B Phadke – Ar Revenue By Shri Keyur Patel – Dr(Cit) Date Of Hearing 01/01/2024 Date Of Pronouncement 05/01/2024

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

…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…

Indian Chamber of Commerce, Kolkata vs. DCIT, Cir-1(1), (Exemption), Kolkata.

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

ITA 934/KOL/2023[2014-15]Status: DisposedITAT Kolkata22 Dec 2023AY 2014-15

Bench: Shri Rajpalyadav, Vice-(Kz) & Shri Rajesh Kumar]

Section 11Section 12ASection 2(15)Section 25

…(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…

Indian Chamber of Commerce., Kolkata vs. DCIT, Cir-1(1), (Exemption), Kolkata

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

ITA 933/KOL/2023[2013-14]Status: DisposedITAT Kolkata22 Dec 2023AY 2013-14

Bench: Shri Rajpalyadav, Vice-(Kz) & Shri Rajesh Kumar]

Section 11Section 12ASection 2(15)Section 25

…(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…

Narada Gana Sabha Trust, Chennai vs. ITO Exemptions Ward-1, Chennai

In the result, appeal filed by the assessee is allowed

ITA 463/CHNY/2023[2018-19]Status: DisposedITAT Chennai10 Nov 2023AY 2018-19

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकरअपीलसं./Ita No.463/Chny/2023 िनधा"रणवष"/Assessment Year: 2018-19 Narada Gana Sabha Trust, The Income Tax Officer- V. No.314, T.T.K.Road, (Exemptions), Alwarpet, Ward-1, Chennai-600 018. Chennai. [Pan: Aaatn 0417 C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri S. Sridhar, AdvFor Respondent: Shri R. Clement Ramesh-
Section 11Section 126Section 2(15)Section 263

…आयकर अपीलीय अिधकरण, ’सी’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI "ी मंजूनाथा.जी, लेखा सद" एवं "ी मनो मोहन दास, "ाियक सद" के सम" BEFORE SHRI MANJUNATHA. G, ACCOUNTANT MEMBER AND SHRI MANOMOHAN DAS, JUDICIAL MEMBER आयकरअपीलसं./ITA No.463/Chny/2023 िनधा"रणवष"/Assessment Year: 2018-19 Narada Gana Sabha Trust, The Income Tax Officer- v. No.314, T.T.K.Road, (Exemptions), Alwarpet, Ward-1, Chennai-600 018. Chennai. [PAN: AAATN 0417 C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Shri S. Sridhar, Adv. ""यथ" क" ओर से /Respondent by : Shri R. Clement Ramesh- Kum…

Bhamashah Sundarlal Daga Charitable Trust, Bikaner vs. CIT - Exemption, Jaipur

The appeal of the assessee is allowed for statistical purpose

ITA 278/JODH/2023[2022-23 to 2026-27]Status: DisposedITAT Jodhpur10 Nov 2023

Bench: Shri Pavan Kumar Gadale & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.278/Jodh/2023 िनधा"रण वष" / Assessment Year : N.A. Bhamashah Sundarlal Daga The Commissioner Of Charitable Trust, V Income Tax-Exemption, Bagree Mohallan, S Jaipur. Bikaner – 334001. Pan: Aaetb1013C Appellant/ Assessee Respondent/ Revenue Assessee By Shri Suresh Ojha – Ar Revenue By Smt. Alka Rajvanshi Jain – Cit(Dr) Date Of Hearing 14/08/2023 Date Of Pronouncement 10/11/2023

Section 12Section 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 7 Bhamashah Sundarlal Daga Charitable Trust [A] 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…

J & K Womens Corporation Limited, Jammu vs. Commissioner of Income Tax (Exemptions), Chandigarh

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

ITA 164/ASR/2020[2020-21]Status: DisposedITAT Amritsar01 Aug 2023AY 2020-21

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.164/Asr/2020 Assessment Years: N/A J & K Women’S Development Vs. Cit (Exemptions) Corporation Ltd., Chandigarh. Auqaf Complex Opposite Government Hospital, Gandhi (Respondent) Nagar, Jammu. [Pan:Aaacj4584F] (Appellant)

Section 11Section 12ASection 2(15)Section 8(5)

…to generate their own resources. The assessee filed an application in Form No.10A and seeking registration u/s 12AA before the ld. CIT(E), Chandigarh. But the ld. CIT(E) considering the order of Hon’ble Apex Court in the case of Sole Trustee Sansthan vs. CIT 101 ITR 234 (SC) had rejected the application of the assessee. Being aggrieved assessee filed an appeal before us. 4. The ld. AR for assessee filed written submissions which are kept in the record. The ld. AR first argued that the ld. CIT(E) had rejected the application on basis of the order of Hon’ble Apex Court in the case of Sole Trustee Sansthan (supra)…

Indian Institute of Banking and Finance ( Formerly Known As the Indian Institute of Bankers), Mumbai vs. CIT (Exemptions), Mumbai

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

ITA 875/MUM/2021[2019-21]Status: DisposedITAT Mumbai17 May 2023AY 2019-21

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Purushottam Tripuri
Section 10Section 10(22)Section 2(15)

…the Tribunal held that the object and activities pursued by the assessee qualify for exemption under section 10(22) of the Act. The coordinate bench also referred to the decision of the Hon‟ble Supreme Court in Sole Trustee Lok Shikshana Trust vs CIT, [1975] 101 ITR 234, which has also been relied upon by the learned CIT(E) in the present case, and held there is nothing in the judgment to suggest that the court meant to convey that educational activities could be pursued only in a formal atmosphere such as a school or college in the sense in which we know them. The coordinate bench after referring to the decisio…

Indian Institute of Banking and Finance ( Formerly Known As the Indian Institute of Bankers), Mumbai vs. CIT (Exemptions), Mumbai

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

ITA 874/MUM/2021[2016-17]Status: DisposedITAT Mumbai17 May 2023AY 2016-17

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Purushottam Tripuri
Section 10Section 10(22)Section 2(15)

…the Tribunal held that the object and activities pursued by the assessee qualify for exemption under section 10(22) of the Act. The coordinate bench also referred to the decision of the Hon‟ble Supreme Court in Sole Trustee Lok Shikshana Trust vs CIT, [1975] 101 ITR 234, which has also been relied upon by the learned CIT(E) in the present case, and held there is nothing in the judgment to suggest that the court meant to convey that educational activities could be pursued only in a formal atmosphere such as a school or college in the sense in which we know them. The coordinate bench after referring to the decisio…

Indian Institution of Banking and Finance (Formerly Known As the India Institute of Bankers), Mumbai vs. CIT (Exemption), Mumbai

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

ITA 6955/MUM/2019[2018-19]Status: DisposedITAT Mumbai17 May 2023AY 2018-19

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Purushottam Tripuri
Section 10Section 10(22)Section 2(15)

…the Tribunal held that the object and activities pursued by the assessee qualify for exemption under section 10(22) of the Act. The coordinate bench also referred to the decision of the Hon‟ble Supreme Court in Sole Trustee Lok Shikshana Trust vs CIT, [1975] 101 ITR 234, which has also been relied upon by the learned CIT(E) in the present case, and held there is nothing in the judgment to suggest that the court meant to convey that educational activities could be pursued only in a formal atmosphere such as a school or college in the sense in which we know them. The coordinate bench after referring to the decisio…

The Indian Institute of Banking & Finance ( Formerly Known As the Indian Insitute of Bankers), Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

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

ITA 7447/MUM/2018[2017-18]Status: DisposedITAT Mumbai17 May 2023AY 2017-18

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Purushottam Tripuri
Section 10Section 10(22)Section 2(15)

…the Tribunal held that the object and activities pursued by the assessee qualify for exemption under section 10(22) of the Act. The coordinate bench also referred to the decision of the Hon‟ble Supreme Court in Sole Trustee Lok Shikshana Trust vs CIT, [1975] 101 ITR 234, which has also been relied upon by the learned CIT(E) in the present case, and held there is nothing in the judgment to suggest that the court meant to convey that educational activities could be pursued only in a formal atmosphere such as a school or college in the sense in which we know them. The coordinate bench after referring to the decisio…

Pr. Commissioner of Income Tax - III vs. Lalit Kumar Biyani

ITA/54/2020HC Rajasthan10 May 2023

Bench: MANINDRA MOHAN SHRIVASTAVA,ANIL KUMAR UPMAN

Section 12ASection 51

…nt-Society had applied f nning a private Industrial Trainin g to the students, and the same w ional Council for Vocational Tra plication was rejected by the CI wledge or skill does not qualif ot come within the four corners f Sole Trustee Loka Shikshan e Tax (101 ITR 234). It further observed that ‘educati de and extended sense, and acq not constitute education. Mer e systematic education. cond ground for rejection was th the character of voluntary don he property cannot be said to be e. The contributions towards orated. The third objection was wi society alleged to be meant for pe t therein) was allowed, an…