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

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1116/BANG/2019[2015-16]Status: DisposedITAT Bangalore06 Apr 2023AY 2015-16

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…ed within the meaning of business or trade, as envisaged under clause (2) of Article 289 read with the Income Tax Act. 2.16 The word business has been explained by the Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT reported in 101 ITR 234 (SC) 2.17 The other word used is trade. The meaning of the word trade has been explained by the Hon’ble Supreme Court in the case of State of Punjab v. Bajaj Electricals Ltd. reported in 70 ITR 730 (SC) ITA Nos.1048 & 1112 to 1116/Bang/2019 Bangalore Metro Rail Corporation Ltd., Bangalore Page 8 of 60 2.18 Thus the ld. A.R. submitted that it…

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1115/BANG/2019[2014-15]Status: DisposedITAT Bangalore06 Apr 2023AY 2014-15

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…ed within the meaning of business or trade, as envisaged under clause (2) of Article 289 read with the Income Tax Act. 2.16 The word business has been explained by the Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT reported in 101 ITR 234 (SC) 2.17 The other word used is trade. The meaning of the word trade has been explained by the Hon’ble Supreme Court in the case of State of Punjab v. Bajaj Electricals Ltd. reported in 70 ITR 730 (SC) ITA Nos.1048 & 1112 to 1116/Bang/2019 Bangalore Metro Rail Corporation Ltd., Bangalore Page 8 of 60 2.18 Thus the ld. A.R. submitted that it…

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle - 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1114/BANG/2019[2013-14]Status: DisposedITAT Bangalore06 Apr 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…ed within the meaning of business or trade, as envisaged under clause (2) of Article 289 read with the Income Tax Act. 2.16 The word business has been explained by the Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT reported in 101 ITR 234 (SC) 2.17 The other word used is trade. The meaning of the word trade has been explained by the Hon’ble Supreme Court in the case of State of Punjab v. Bajaj Electricals Ltd. reported in 70 ITR 730 (SC) ITA Nos.1048 & 1112 to 1116/Bang/2019 Bangalore Metro Rail Corporation Ltd., Bangalore Page 8 of 60 2.18 Thus the ld. A.R. submitted that it…

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle - 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1113/BANG/2019[2012-13]Status: DisposedITAT Bangalore06 Apr 2023AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…ed within the meaning of business or trade, as envisaged under clause (2) of Article 289 read with the Income Tax Act. 2.16 The word business has been explained by the Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT reported in 101 ITR 234 (SC) 2.17 The other word used is trade. The meaning of the word trade has been explained by the Hon’ble Supreme Court in the case of State of Punjab v. Bajaj Electricals Ltd. reported in 70 ITR 730 (SC) ITA Nos.1048 & 1112 to 1116/Bang/2019 Bangalore Metro Rail Corporation Ltd., Bangalore Page 8 of 60 2.18 Thus the ld. A.R. submitted that it…

M/S. Bangalore Metro Rail Corporation Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle - 1(1)(2), Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1112/BANG/2019[2011-12]Status: DisposedITAT Bangalore06 Apr 2023AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…ed within the meaning of business or trade, as envisaged under clause (2) of Article 289 read with the Income Tax Act. 2.16 The word business has been explained by the Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT reported in 101 ITR 234 (SC) 2.17 The other word used is trade. The meaning of the word trade has been explained by the Hon’ble Supreme Court in the case of State of Punjab v. Bajaj Electricals Ltd. reported in 70 ITR 730 (SC) ITA Nos.1048 & 1112 to 1116/Bang/2019 Bangalore Metro Rail Corporation Ltd., Bangalore Page 8 of 60 2.18 Thus the ld. A.R. submitted that it…

Additional Commissioner of Income Tax, Special Range - 1, Bangalore vs. M/S. Bangalore Metro Rail Corporation Limited, Bangalore

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

ITA 1048/BANG/2019[2011-12]Status: DisposedITAT Bangalore06 Apr 2023AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

For Appellant: Shri Srihari Kutsa, A.RFor Respondent: Shri Sankar Ganesh K., D.R
Section 2Section 3

…ed within the meaning of business or trade, as envisaged under clause (2) of Article 289 read with the Income Tax Act. 2.16 The word business has been explained by the Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT reported in 101 ITR 234 (SC) 2.17 The other word used is trade. The meaning of the word trade has been explained by the Hon’ble Supreme Court in the case of State of Punjab v. Bajaj Electricals Ltd. reported in 70 ITR 730 (SC) ITA Nos.1048 & 1112 to 1116/Bang/2019 Bangalore Metro Rail Corporation Ltd., Bangalore Page 8 of 60 2.18 Thus the ld. A.R. submitted that it…

Equitas Development Initiatives Trust, Chennai vs. ITO Exemption Ward-3, Chennai

In the result, the appeals filed for all three assessment years are allowed for statistical purposes

ITA 2583/CHNY/2019[2012-13]Status: DisposedITAT Chennai18 Nov 2022AY 2012-13

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2582, 2583 & 2082/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13 & 2013-14

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

…ies carried out by the assessee neither comes under definition of education nor in the nature of relief to the poor. The ld. CIT(A) has discussed the issue in light of decision of Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs CIT, 101 ITR 234 (SC), and held that in order to come under definition of education, a formal education given to the young in preparing for the work of life is only to be considered as education, but not providing or conducting a coaching classes. Therefore, rejected arguments of the assessee and sustained additions made by the AO towards rejection of exemption c…

Equitas Development Initiatives Trust, Chennai vs. ITO Exemption Ward-3, Chennai

In the result, the appeals filed for all three assessment years are allowed for statistical purposes

ITA 2582/CHNY/2019[2011-12]Status: DisposedITAT Chennai18 Nov 2022AY 2011-12

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2582, 2583 & 2082/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13 & 2013-14

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

…ies carried out by the assessee neither comes under definition of education nor in the nature of relief to the poor. The ld. CIT(A) has discussed the issue in light of decision of Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs CIT, 101 ITR 234 (SC), and held that in order to come under definition of education, a formal education given to the young in preparing for the work of life is only to be considered as education, but not providing or conducting a coaching classes. Therefore, rejected arguments of the assessee and sustained additions made by the AO towards rejection of exemption c…

Equitas Development Initiatives Trust, Chennai vs. ITO Exemption Ward-3, Chennai

In the result, the appeals filed for all three assessment years are allowed for statistical purposes

ITA 2082/CHNY/2019[2013-14]Status: DisposedITAT Chennai18 Nov 2022AY 2013-14

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2582, 2583 & 2082/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13 & 2013-14

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

…ies carried out by the assessee neither comes under definition of education nor in the nature of relief to the poor. The ld. CIT(A) has discussed the issue in light of decision of Hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs CIT, 101 ITR 234 (SC), and held that in order to come under definition of education, a formal education given to the young in preparing for the work of life is only to be considered as education, but not providing or conducting a coaching classes. Therefore, rejected arguments of the assessee and sustained additions made by the AO towards rejection of exemption c…

ITO (Exemptions), Ward-1(2), New Delhi vs. Indian Olympic Association, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 7678/DEL/2018[2015-16]Status: DisposedITAT Delhi10 Nov 2022AY 2015-16

Bench: Shri Anil Chaturvedi & Shri Anubhav Sharma

For Appellant: Shri Hiren Mehta, C.AFor Respondent: Shri Anuj Garg, Sr. D.R
Section 11Section 143(2)Section 143(3)Section 2(15)

…s not only in India but also in international forum. The impugned association would not lose its character of charitable purpose merely because some sponsorship was accepted. 26. In the case of Sole Trustee, Loka Shikshana Trust v. Commissioner of Income-tax 101 ITR 234, the Hon'ble Justice J. Baig speaking for the Apex Court thus said that: 8 ITA.No.7678/Del./2018 M/s .Indian Olympic Association, New Delhi. "If the profits must necessarily feed a charitable purpose, under the terms of the trust, the mere fact that the activities of the trust yield profit will not alter the charitable character of the trust.…

Umak Education Trust, Delhi vs. JCIT (E), Range- 2, Delhi

ITA 690/DEL/2019[2014-15]Status: DisposedITAT Delhi02 Nov 2022AY 2014-15

Bench: Shri Anil Chatrurvedi & Shri Anubhav Sharmaumak Education Trust, Vs. Jcit(E), S-135, Greater Kailash Ii, Range-2, New Delhi Delhi (Appellant) (Respondent) Pan: Aaatu2598P

For Appellant: Ms. Kanika Jain, CAFor Respondent: Shri Abhishek Kumar, Sr. DR
Section 11Section 12ASection 142(1)Section 143(2)Section 143(3)Section 194Section 194JSection 80G(5)(vi)

…d and needy.” 12. It was submitted that the ld AO has cherry picked certain judgments in favour of the assessee and ld AR distinguished the judgment relied by the Ld. AO submitting that the judgment in case of Sole Trustee Lok Shikshana Trust Vs. CIT, (1975) 101 ITR 234, Bihar Institute of Mining & Surveying Vs. CIT (1994) 208 ITR 608, Delhi Music Society Vs. Director General of Income Tax (2012) 17 taxman.com 49 (Delhi), were the decisions which were distinguishable on facts had the ld AO considered the judgments cited on behalf of the assessee. Referring to the judgment of the Institute of Chartered Accountant…

M/S New Noble Educational Society vs. The Chief Commissioner of Income Tax 1

The appeals are hereby dismissed, without order on costs

C.A. No.-003795-003795 - 2014Supreme Court19 Oct 2022

Bench: HON'BLE THE CHIEF JUSTICE

Section 10

…ion of further knowledge constitutes education. What education connotes, in that clause, is the process of training and developing the knowledge, skill, mind and character of students by formal schooling. (Sole Trustee, Loka Shikshana Trust v. CIT, [1975] 101 ITR 234 (SC)). This definition of “education” is wide enough to cover the case of an “educational institution” as, under section 10(23C)(vi), the “educational institution” must exist “solely” for educational purposes. (Maharaja Sawai Mansinghji Museum Trust, [1988] 169 ITR 379 (Raj)). The element of imparting education to students or the element of n…

Imc Chamber of Commerce and Industry (Formerly Indian Merchants Chamber), Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

In the result, appeals filed by the assessee are allowed

ITA 6703/MUM/2017[2016-17]Status: DisposedITAT Mumbai27 Sept 2022AY 2016-17

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble&

Section 10Section 2(15)Section 25

…t Art Silk Cloth Manufacturers Association dated 19.11.1979 and discussed the case of Indian Chambers of Commerce v. CIT in detail and they observed as under: - “We must, however, refer to the decision of this court in Indian Chamber of Commerce v. CIT [1975] 101 ITR 796 because that is the decision on which the strongest reliance was placed on behalf of the revenue. The question which arose for decision in that case was whether income derived by the Indian Chamber of Commerce from arbitration fees levied by the Chamber, fees collected for issuing certificates of origin and share of profit for issue of certificat…

The Rediant Way School, Raipur (Cg) vs. The the Chif Commisioner of Income Tax, Raipur (Cg)

In the result, the appeal of assessee is allowed

ITA 15/BIL/2017[2013-14]Status: DisposedITAT Raipur21 Sept 2022AY 2013-14
For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri P.K.Mishra, CIT-DR
Section 10Section 253

…tinctive, independent, distributive and perused independently of others. While deciding the issue on legal and factual aspect the CCIT has observed and relied on a judgment by Hon‟ble Supreme Court in the case of Sole Trustee, Loka Sikshan Trust Vs CIT (1975) 101 ITR 234, wherein the interpretation of word Education has been elaborately expounded, held as under: 6 'The sense in which the word "education" has been used in Section 2(15) is the systematic 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 pe…

Jt. Comm of Income Tax(OSD) (E) -2(1), Mumbai vs. Maharashtra State Road Transport Corporation, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1500/MUM/2022[2014-15]Status: DisposedITAT Mumbai20 Sept 2022AY 2014-15
Section 11Section 12ASection 2(15)

…e Gujarat High Court understood such activities to be falling within the expression 'education'. In coming to such a conclusion, the Hon'ble Court referred to the judgment of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT, 101 ITR 234 (SC) to contend that the word 'education' should not be confined only to scholastic instructions, but other forms of education are also included in the expression 'education'. Though the decision of the Hon'ble Gujarat High Court is in the context of Sec. 10(22) of the Act, yet, it is of relevance for us since it has explained the meaning of the…

Jt. Comm of Income Tax(OSD) (E) -2(1), Mumbai vs. Maharashtra State Road Transport. Corporation, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1496/MUM/2022[2009-10]Status: DisposedITAT Mumbai20 Sept 2022AY 2009-10
Section 11Section 12ASection 2(15)

…e Gujarat High Court understood such activities to be falling within the expression 'education'. In coming to such a conclusion, the Hon'ble Court referred to the judgment of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust vs. CIT, 101 ITR 234 (SC) to contend that the word 'education' should not be confined only to scholastic instructions, but other forms of education are also included in the expression 'education'. Though the decision of the Hon'ble Gujarat High Court is in the context of Sec. 10(22) of the Act, yet, it is of relevance for us since it has explained the meaning of the…

The Commissioner of Income Tax, Hyd vs. Cargo Handling Private Workers Pool, Visakhapatnam

Accordingly, the I.T.T.A. is dismissed

ITTA/14/2017HC Andhra Pradesh15 Sept 2022

Bench: C.PRAVEEN KUMAR,TARLADA RAJASEKHAR RAO

Section 11Section 11(5)Section 13(1)(c)Section 143(1)Section 147Section 148Section 260

…ourt in Sole Trustee, Loka Shikshana Trust V. Commissioner of Income-Tax, Mysore1 to contend that the principles laid down establish the fact that the activities of the assessee trust have 1 [1975] 101 ITR 234 (SC) 6 been carried on, right from inception, only in advancement of general public utility, as ordained in Clause-3 of the Trust Deed. (iii) Insofar as advancement of loans of Rs.30.00 lakhs and Rs.5.00 lakhs to the two settler associations, it is pleaded that in case of Visakhapatnam Customs Clearance and Forwarding Agents Associatio…

Naya Raipur Development Authority, Raipur vs. Assistant Commissioner of Income Tax (Exemption), Raipur

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 63/RPR/2019[2013-14]Status: DisposedITAT Raipur02 Sept 2022AY 2013-14

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 174 & 63/Rpr/2019 "नधा"रण वष" / Assessment Year(S) : 2012-13 & 2013-14 Naya Raipur Development Authority Prayavas Bhawan, North Block, Sector 19, Naya Raipur Marg, Naya Raipur, Atal Nagar(C.G.) Pin-492 002. Pan : Aaalc0225H .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax (Exemption) Raipur (C.G.) ……""यथ" / Respondent Assessee By : S/Shri S.R Rao & Rajesh Kumar Chawda, Ar’S. Revenue By : Shri P.K. Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 09.06.2022 घोषणा क" तार"ख / Date Of Pronouncement : 02.09.2022

For Appellant: S/shri S.R Rao & Rajesh KumarFor Respondent: Shri P.K. Mishra, CIT-DR
Section 11Section 12ASection 143(2)Section 143(3)Section 2(15)Section 64Section 65Section 68

…आयकर अपील"य अ"धकरण "यायपीठ रायपुर म"। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI RATHOD KAMLESH JAYANTBHAI, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No. 174 & 63/RPR/2019 "नधा"रण वष" / Assessment Year(s) : 2012-13 & 2013-14 Naya Raipur Development Authority Prayavas Bhawan, North Block, Sector 19, Naya Raipur Marg, Naya Raipur, Atal Nagar(C.G.) Pin-492 002. PAN : AAALC0225H .......अपीलाथ" / Appellant बनाम / V/s. The Deputy Commissioner of Income Tax (Exemption) Raipur (C.G.) ……""यथ" / Respondent Assessee by : S/shri S.R Rao & Rajesh Kumar Chawda, A…

Naya Raipur Development Authority, Raipur vs. Deputy Commissioner of Income Tax (Exemption), Raipur

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 174/RPR/2019[2012-13]Status: DisposedITAT Raipur02 Sept 2022AY 2012-13

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 174 & 63/Rpr/2019 "नधा"रण वष" / Assessment Year(S) : 2012-13 & 2013-14 Naya Raipur Development Authority Prayavas Bhawan, North Block, Sector 19, Naya Raipur Marg, Naya Raipur, Atal Nagar(C.G.) Pin-492 002. Pan : Aaalc0225H .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax (Exemption) Raipur (C.G.) ……""यथ" / Respondent Assessee By : S/Shri S.R Rao & Rajesh Kumar Chawda, Ar’S. Revenue By : Shri P.K. Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 09.06.2022 घोषणा क" तार"ख / Date Of Pronouncement : 02.09.2022

For Appellant: S/shri S.R Rao & Rajesh KumarFor Respondent: Shri P.K. Mishra, CIT-DR
Section 11Section 12ASection 143(2)Section 143(3)Section 2(15)Section 64Section 65Section 68

…आयकर अपील"य अ"धकरण "यायपीठ रायपुर म"। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI RAVISH SOOD, JUDICIAL MEMBER AND SHRI RATHOD KAMLESH JAYANTBHAI, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No. 174 & 63/RPR/2019 "नधा"रण वष" / Assessment Year(s) : 2012-13 & 2013-14 Naya Raipur Development Authority Prayavas Bhawan, North Block, Sector 19, Naya Raipur Marg, Naya Raipur, Atal Nagar(C.G.) Pin-492 002. PAN : AAALC0225H .......अपीलाथ" / Appellant बनाम / V/s. The Deputy Commissioner of Income Tax (Exemption) Raipur (C.G.) ……""यथ" / Respondent Assessee by : S/shri S.R Rao & Rajesh Kumar Chawda, A…

Imc of I.T.I. Barwala Society, Haryana vs. CIT(E), Chandigargh

In the result, the appeal filed by the Appellant stands allowed

ITA 7889/DEL/2019[2019-20]Status: DisposedITAT Delhi29 Aug 2022AY 2019-20

Bench: Dr. B.R.R. Kumar & Shri N.K. Choudhryimc Of I.T.I., C/O Iti Versus C.I.T. (Exemptions) Barwala, Jind Road, Chandigarh. Barwala, Hisar. Pan: Aaaai2715F (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri Ravi KantChoudhary, Ld. Sr. DR
Section 11Section 12Section 12ASection 2(15)

…l training. In that light, the applicant has claimed that its activities fall under ‘education’. However, the sense in which the word “education” has been used in section 2(15) as interpreted by the Apex Court in the case of Sole trustee, LokaSikshanSansthan (101 ITR 234) is 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 “education” has not been used in that wide and extended sense, according to which every acquisition of further knowledge constitutes education.…