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Sole Trustee Loka Shikshana Turst vs Commissioner Of Income Tax, Mysore on 28 August, 1975

6. The AO was, however, of the view that the assessee provided technical services to various companies and fee was received for professional/ technical services. The term "education" means to bring up children by training them properly whereas, in the instant case, the courses offered by the assessee are not recognised as such by any competent authority. The assessee institute has not got any recognition either from the state or central government. In this regard he relied upon the decision in the case of Bihar Institute of Mining & Mine Surveying 208 ITR 608 (Patna) wherein it was held that the institution which was not authorised, cannot be said to have any element of normal schooling. He thus concluded that the activities of consultancy and technical & professional services for which the institute receives payment are not certainly an educational activity but they are the jobs done for third parties against consideration. The AO distinguished the decisions of the Apex Court in the case of Sole Trustee, Lok Sikshana Trust vs. CIT 101 ITR 234 as well as the decision of the Hon'ble Gujarat High Court in the case of Gujarat State Cooperative Union vs. CIT 195 ITR 279. On the facts of the aforesaid cases the activities of developing bankers and finance professionals are different from fees collected by the assessee from different parties. In his opinion there should be formal education who, in turn, should appear for a particular examination such as diploma/engineering course. He thus concluded that the income earned by the assessee-trust cannot be treated as income from educational activity and hence it has to be treated as business income.
Supreme Court of India Cites 24 - Cited by 2203 - H R Khanna - Full Document

Gujarat State Co-Operative Union vs Commissioner Of Income-Tax on 7 February, 1992

6. The AO was, however, of the view that the assessee provided technical services to various companies and fee was received for professional/ technical services. The term "education" means to bring up children by training them properly whereas, in the instant case, the courses offered by the assessee are not recognised as such by any competent authority. The assessee institute has not got any recognition either from the state or central government. In this regard he relied upon the decision in the case of Bihar Institute of Mining & Mine Surveying 208 ITR 608 (Patna) wherein it was held that the institution which was not authorised, cannot be said to have any element of normal schooling. He thus concluded that the activities of consultancy and technical & professional services for which the institute receives payment are not certainly an educational activity but they are the jobs done for third parties against consideration. The AO distinguished the decisions of the Apex Court in the case of Sole Trustee, Lok Sikshana Trust vs. CIT 101 ITR 234 as well as the decision of the Hon'ble Gujarat High Court in the case of Gujarat State Cooperative Union vs. CIT 195 ITR 279. On the facts of the aforesaid cases the activities of developing bankers and finance professionals are different from fees collected by the assessee from different parties. In his opinion there should be formal education who, in turn, should appear for a particular examination such as diploma/engineering course. He thus concluded that the income earned by the assessee-trust cannot be treated as income from educational activity and hence it has to be treated as business income.
Gujarat High Court Cites 10 - Cited by 54 - Full Document

Dit (Exemptions) vs National Safety Council on 22 January, 2008

In this regard he referred to the decision of the Hon'ble Bombay High Court in the case of DIT vs. National Safety Council 305 ITR 257 and contended that merely because some courses are not recognised by DG Shipping it cannot be a ground for denial of exemption under section 11 of the Act. The learned counsel also referred to circular No. 11 of 2008 dated 19th December, 2008 issued by CBDT wherein the Board observed that having regard to the number of entities engaged in commercial activities the expression 'advancement of any other object of general public utility' was amended by Finance Act, 2008 but the newly inserted first proviso to section 2(15) will not apply where the purpose of the trust or institution is education even if it incidentally involves 7 ITA No. 5973/Mum/2013 St. Joseph's Technical School commercial activity. In other words, the view of the CBDT was that so long as the case of the assessee falls within the broader spectrum of advancement of general public utility it may amount to charitable purpose. In the instant case the assessee was mainly engaged in imparting technical training which were approved by the NCVT. By letting out the premises, the space is utilised for training the Jet Airways employees and others to obtain technical knowledge wherein the assessee was also imparting training and had the benefit of the lab, etc., provided by them, and thus the rental income and income received for services rendered cannot be treated as commercial activity since it is for the advancement of the object of general public utility.
Bombay High Court Cites 7 - Cited by 6 - R S Mohite - Full Document
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