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2014 (1) TMI 186 - AT - Income TaxApplication for registration u/s 12AA - Held that:- Following Sole Trustee, Loka Shikshana Trust vs Commissioner of Income-tax [1975 (8) TMI 1 - SUPREME Court] - All kinds of acquiring knowledge will not come within the meaning of “education”. What “education” connotes in section 2(15) is the processing of training and developing the knowledge, skill, mind and character of students by normal schooling - 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 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 - Mere coaching classes may provide some kind of knowledge to the students. But that kind of acquisition of knowledge through coaching classes cannot fall within the meaning of “education” as provided in section 2(15) of the Act - There should be a normal schooling by way of regular and systematic instruction - Following Bihar Institute of Mining And Mine Surveying vs C.I.T. [1993 (12) TMI 50 - PATNA High Court] - The word “charitable” prefixing the word “institution” has to be given its full effect - It appears that one of the principal projects of the petitioner’s institution has the object of coaching and preparing the students for appearing in various examinations conducted by the Board of Mining Examination and / or MI (1) section (a)(b) and the said coaching of students in an institute is not, an imparting of education which can be said to be a process of training and developing knowledge and character of students by normal schooling - A coaching institute cannot be said to be an institution where normal schooling is done - The assessee cannot be considered to be an “educational trust” within the meaning of section 2(15) of the Act - It is not entitled for registration u/s 12AA of the Act - Decided against assessee.
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