[Cites 10, Cited by 0]
Karnataka High Court
M/S Deshpande Education Trust vs The Assistant Commissioner Of on 17 December, 2025
Author: S G Pandit
Bench: S G Pandit
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ITA No.100009 of 2017
IN THE HIGH COURT OF KARNATAKA, AT DHARWAD
DATED THIS THE 17TH DAY OF DECEMBER, 2025
PRESENT
THE HON'BLE MR. JUSTICE S G PANDIT
AND
THE HON'BLE MRS JUSTICE GEETHA K.B.
ITA NO.100009 OF 2017
BETWEEN:
M/S DESHPANDE EDUCATION TRUST
DCSE BUILDING, BVBCET CAMPUS,
VIDYANAGAR, HUBLI-580031.
(R/BY ITS MANAGING TRUSTEE,
SRI. NAVEEN JHA, S/O UDAI CHAND JHA
AGED ABOUT 39 YEARS)
...APPELLANT
(BY SRI. CHYTHANYA K.K., SENIOR COUNSEL FOR
SRI. S. SHARATH AND SRI. SHASHANK HEGDE, ADVOCATES)
AND:
1. THE ASSISTANT COMMISSIONER OF
INCOME TAX CIRCLE 1(1),
C.R. BUILDING, NAVANAGAR, HUBLI-580 025.
2. THE DEPUTY COMMISSIONER OF
VISHAL INCOME TAX CIRCLE 1(1),
NINGAPPA
PATTIHAL C.R. BUILDING, NAVANAGAR, HUBLI-580 025.
Digitally signed by
VISHAL NINGAPPA
PATTIHAL ...RESPONDENTS
Location: HIGH COURT
OF KARNATAKA
DHARWAD BENCH (BY SRI. M. THIRUMALESH, ADVOCATE)
THIS ITA IS FILED UNDER SEC.260A OF THE INCOME-TAX ACT
1961, PRAYING TO FORMULATE THE SUBSTANTIAL QUESTION OF LAW
AND ALLOW THE APPEAL AND SET ASIDE THE IMPUGNED ORDER OF
THE INCOME-TAX APPELLATE TRIBUNAL, BENGALURU 'A' BENCH
BEARING IN ITA NO.1422 AND 1423/BANG/2016, DATED 13.10.2016
FOR THE ASSESSMENT YEARS 2011-12 AND 2012-13 & ETC.
THIS ITA HAVING BEEN HEARD AND RESERVED ON 11.11.2025
AND COMING ON FOR PRONOUNCEMENT OF JUDGMENT THIS DAY,
S G PANDIT J., DELIVERED THE FOLLOWING:
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ITA No.100009 of 2017
CORAM: THE HON'BLE MR. JUSTICE S G PANDIT
AND
THE HON'BLE MRS JUSTICE GEETHA K.B.
CAV JUDGMENT
(PER: THE HON'BLE MR. JUSTICE S G PANDIT)
The assessee-M/s Deshpande Education Trust1 is in
appeal under Section 260A of the Income Tax Act, 19612
aggrieved by the Order of the Income Tax Appellate Tribunal,
'A' Bench, Bengaluru3 dated 13.10.2016 in ITA Nos. 1422 and
1423 (Bang) 2016 for the assessment years4 2011-12 and
2012-13, wherein, the appeals filed by the appellant
challenging the orders of the learned Commissioner of Income
Tax (Appeals), Hubli5 were dismissed.
2. The appeal was admitted on 20.11.2017 to
examine the following substantial questions of law:
i. Whether, in the facts and in the circumstances of
the case, the Tribunal was right in law in holding
that the activity of the appellant is not education
but 'advancement of any other object of general
public utility'?
1 Hereinafter referred to as 'Appellant'
Hereinafter referred to as 'The Act'
Hereinafter referred to as 'Tribunal'
Hereinafter referred to as 'AY'
Hereinafter referred to as 'CIT(A)'
ii. Without prejudice to the above, whether in the
facts and in the circumstances of the case, the
Tribunal is right in holding that activity of the
appellant is in the nature of trade, commerce or
business and hit by the first proviso to section
2(15)?
iii. Whether, the finding of the Tribunal that the
appellant is collecting hefty fee, making huge
profits and carrying business is perverse?
BRIEF FACTS:
3. The appellant is a registered trust under Section
12AA of the Act engaged in the activity of running coaching
classes and training programmes for skill development and
vocational training to students by charging fees. The appellant
filed the return of income for AYs 2011-12 and 2012-13
declaring nil income on 26.07.2011 and 26.09.2012,
respectively. The case of the appellant for AY 2011-12 was
selected for scrutiny and notices under Section 143(2) and
Section 142(1) were issued to the appellant on 20.09.2012.
Subsequently, the case of the appellant for AY 2012-13 was
selected for scrutiny and notice under Section 143(2) and
notice under Section 142(1) were issued to the appellant on
18.09.2013 and 15.10.2014, respectively.
4. The Respondent No.2-Assessing Officer6 passed the
assessment Order for AY 2011-12 under Section 143(3) of the
Act on 29.11.2013 denying the exemption claimed by the
appellant under Section 11 of the Act and assessing the total
income of the appellant at Rs. 6,19,527/-. Further,
Respondent No.3-AO passed the assessment Order for AY
2012-13 under Section 143(3) of the Act on 14.11.2014
denying the exemption claimed by the appellant under Section
11 of the Act and assessing the total income of the appellant
at Rs.3,41,730/-.
5. Aggrieved by the orders of the AO, the appellant
filed appeals before the Learned CIT(A) for both the AYs 2011-
12 and 2012-13 which came to be dismissed on 08.02.2016
and 31.03.2016, respectively. Challenging the Orders of the
Learned CIT(A), the appellant filed appeals before the
Tribunal. The Tribunal vide common impugned Order dated
13.10.2016 has dismissed the appeals filed by the Appellant
and has held that activity of the appellant is in the nature of
'advancement of any other object of general public utility' and
6 Hereinafter referred to as 'AO'
the proviso to Section 2(15) of the Act gets attracted and
hence, the appellant shall not be entitled to exemption under
Section 11 of the Act. Hence, the present appeal.
6. Heard learned senior counsel Sri. Chythanya K.K.
for learned counsels Sri. S Sharath and Sri. Shashank Hegde
for the appellant and learned counsel Sri. Thirumalesh for
Respondents-Revenue Authorities.
7. Learned senior counsel Sri. Chythanya K.K. would
submit that the Appellant is engaged in the activity of training
rural youth to develop their skills in the area of science,
technology, arts, etc. by providing various programmes in
order to make them employable. He would submit that the
activity of running coaching classes, done in a systematic
manner by providing training or instructions to students is
covered under the ambit of 'education' as employed in Section
2(15) of the Act. Learned Senior Counsel has relied upon a
catena of decisions to submit that the activity of running
vocational training or coaching classes is covered under the
term 'education'. He would further submit that the mere
existence of profits or the mere generation of surplus from the
activities carried out by the appellant would not mean that the
activities carried on by the appellant is in the nature of
business, trade or commerce. Learned senior counsel would
also submit that the 1st proviso to Section 2(15) of the Act
does not apply to the appellant, as the activities carried on by
the appellant is in the nature of 'education' and not
'advancement of any other object of general public utility'. In
the alternative, learned senior counsel for the appellant would
also submit that, even if the activities of the appellant is
classified as falling under 'advancement of any other object of
general public utility', exemption is ought to be granted to the
appellant, as the objects of the appellant neither involve any
trade, commerce or business nor involve any profit motive.
Thus, learned senior counsel would pray for allowing the
appeal.
8. Per Contra, learned counsel for the Revenue, Sri.
Thirumalesh would submit that the activities that the appellant
is engaged in is rightly classified as falling under
'advancement of any other object of general public utility' by
the Learned AO, CIT(A) and the Tribunal. He would submit
that the appellant's activities for the year under consideration
is to run coaching classes by collecting hefty fees and hence,
would not fall under the ambit of 'education'. Learned counsel
for the revenue would also submit that the appellant has failed
to produce relevant documentary evidence before the
authorities below to prove that the appellant's object is that of
charitable purpose, i.e. education to be specific. He would
further submit that the appellant's activities are in the nature
of trade, commerce or business and hence the 1st proviso to
Section 2(15) of the Act is attracted. Thus, he would pray for
dismissing the appeal.
9. Having heard the learned counsels for the parties
and having perused the entire appeal papers, the fulcrum of
the appeal lies in the issue as to whether activities engaged in
by the appellant can be construed as 'education' as employed
in the definition of 'charitable purposes' under Section 2(15) of
the Act. Section 2(15) of the Act reads as follows:
"(15) "charitable purpose" includes relief of the
poor, education, yoga, medical relief, preservation
of environment (including watersheds, forests and
wildlife) and preservation of monuments or places
or objects of artistic or historic interest, and the
advancement of any other object of general public
utility:
Provided that the advancement of any other object
of general public utility shall not be a charitable
purpose, if it involves the carrying on of any activity
in the nature of trade, commerce or business, or
any activity of rendering any service in relation to
any trade, commerce or business, for a cess or fee
or any other consideration, irrespective of the
nature of use or application, or retention, of the
income from such activity, unless--
(i)such activity is undertaken in the course of actual
carrying out of such advancement of any other
object of general public utility; and
(ii) the aggregate receipts from such activity or
activities during the previous year, do not exceed
twenty per cent of the total receipts, of the trust or
institution undertaking such activity or activities, of
that previous year;"
10. The term 'education' has not been defined in the
Act. However, the Hon'ble Apex Court in Lok Shikshana
Trust v. CIT, reported in (1976) 1 SCC 254 has explained
the term 'education' as employed in Section 2(15) of the Act
and held as under:
"5. 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 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. According to this wide and extended
sense, travelling is education, because as a result of
travelling you acquire fresh knowledge. Likewise, if
you read newspapers and magazines, see pictures,
visit art galleries, museums and zoos, you thereby
add to your knowledge. Again, when you grow up
and have dealings with other people, some of whom
are not straight, you learn by experience and thus
add to your knowledge of the ways of the world. If
you are not careful, your wallet is liable to be stolen
or you are liable to be cheated by some
unscrupulous person. The thief who removes your
wallet and the swindler who cheats you teach you a
lesson and in the process make you wiser though
poorer. If you visit a night club, you get acquainted
with and add to your knowledge about some of the
not much revealed realities and mysteries of life. All
this in a way is education in the great school of life.
But that is not the sense in which the word
"education" is used in clause (15) of Section 2.
What education connotes in that clause is the
process of training and developing the
knowledge, skill, mind and character of
students by formal schooling."
(emphasis supplied)
11. The Hon'ble Apex Court has clarified that
'education' connotes the process of training and developing
the knowledge, skill, mind and character of students by formal
schooling. Thus, the test which has been laid by the Apex
Court in Lok Shikshana Trust (supra) is as to whether a
formal and systematic process of imparting education has
been followed. It is clear that 'education' as under Section
2(15) of the Act needs to be given a wide definition and not
merely restricted to that of 'school' or 'collegiate' education,
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however, the same needs to be in consonance with the test
laid down supra. It is in line with the aforesaid principles, that
the appellant's case needs to be decided.
12. It is not in dispute that the appellant is engaged in
the activity of providing vocational training to rural youth to
develop their skills in the area of science, technology, arts,
etc. by providing various programmes in order to make them
employable in exchange of fees. The Trust Deed dated
04.09.2010 was placed on record before this Court which sets
out the objectives of the trust. The relevant extract of the
objectives of the trust is reproduced hereunder: -
"The objectives of the Trust shall be wholly for the
public and charitable purposes and the income shall be
applied for the same and accumulated in India wholly
for public & charitable purposes. Without prejudice to
generality of foregoing, the following shall be deemed
to be the principal objectives of Deshpande
Educational Trust
I. To establish, own, run, takeover or manage and
maintain or contribute towards establishment
and maintenance of schools, colleges, libraries,
institutes, training institutes, and programs of
study with an object to provide sound pre-
primary, primary, middle, secondary, senior
secondary higher, graduate and post-graduate
education to children and students by seeking
recognition and to give instruction and training
to faculty, students, and educators in all
branches of knowledge and leaming including,
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but not limited to, arts, science and commerce,
management, human resources, medical,
engineering, information technology, leadership,
entrepreneurship and innovation.
II. To focus on, engage, promote, and incubate
activities and programs related to, but not
limited to, youth development, budding
entrepreneurs, local leadership, vocational
training, high-end technology, community
collaboration, product design, social enterprise,
and mentorship.
III. To foster and inculcate the culture of
innovation, entrepreneurship, w scale/growth,
and leadership within the nation's educational
system and programs, including activities
related to education and its improvement.
IV. To arrange and manage the training
institutions in computers and technology, fine
arts, music, painting, modeling, dancing, yoga,
physical education and in other professional
training subjects.
V. To conduct research in education and other
disciplines on different subjects relating to, but
not limited to, education, impact measurement,
curriculum development, training programs,
survey design, leadership development, student
assessment, health, education, agriculture,
livelihoods, the environment, gender, child
rights and disability
VI. To promote literacy, cultural and other social
activities by awareness programs/adult
education classes, lectures, exhibitions,
symposiums, cultural programs, press
conferences, workshops, conferences and
seminars.
VII. To provide and facilitate infrastrücture
pertaining to and supporting education,
including but not limited to food, clothes, books,
medical aid, stationary, transportations
/conveyance, libraries, laboratories, reading
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rooms, hostels, play grounds, swimming pools
and other facilities to students, teaching and
non-teaching staff and also to members of the
society
VIII. To promote prizes, scholarships, exhibitions
and funds for the purpose of promoting and
improving the education of all branches of
knowledge and learning.
IX. To arrange and organize various kinds of
child development and empowerment programs/
activities
X. To facilitate the exchange of ideas and
knowledge between members and the larger
society (as defined by local, state-wide,
national, or international parties interested in
and working in the field of education), and the
community in general by holding lectures,
seminars, discussion groups, exchange,
conferences, and workshops or other means,
and to establish and maintain libraries of
pertinent publications
XI. To pay tuition fees, examination fees,
boarding and lodging fees to deserving students
and to supply books and educational materials
at a market price, subsidized rate or free of cost
to such students.
XII. To establish a hostel with all amenities for
the students and other teaching/non-teaching
staff.
XIII. To conduct leadership, entrepreneurship,
high-technology and, management education
programs for the corporate, non-governmental
organizations, government institutions and other
private sector entities. and organizations,
including funding faculties to conduct such
programs.
XIV. To conduct and facilitate trainings for
faculty, educators, and corporations on subjects
including, but not limited to, curriculum
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development, management, entrepreneurship,
leadership, organization building and innovation.
XV. To affiliate with national and international
universities, institutions, autonomous bodies,
centers, governments, funding agencies
(including private, bi- and multi-lateral
agencies), corporations, social enterprises and
other leading educational institutions including
e-learning programs or distance learning
institutions.
XVI. To publish books, magazines, case studies,
literature, research articles, journals, videos,
photographs, audiovisual materials, websites,
blogs, and other content by utilizing the
expertise available in house and from other
resource persons.
XVII. To aid, assist, donate or otherwise
contribute funds to societies, institutions, trusts
and other funds recognized under Section 80
(G) of the Income Tax Act, 1961.
XVIII. To do such other things/acts/activities,
which are necessary and which may be
incidental or conducive to the attainment of any
of the object of the Trust.
XIX. To devote resources for advancing finance to
poor and needy students for their education and
to identify such students in order to give
them this benefit."
13. As seen from the objectives, the appellant trust
was formed for the purpose of undertaking charitable activities
through education for the empowerment of the
underprivileged, poor and women viz vocational training and
skill development. A coordinate bench of the High Court of
Punjab and Haryana in Commissioner of Income Tax
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(Exemptions) v. Unique Educational Society reported in [2024]
168 taxmann.com 448 (P & H), held that vocational education
is a form of education and that it has been recognized to be,
as important as any other field of education. The relevant
extract of the judgement reads as under:
"14.In view of above, the law as laid down by the
Supreme Court requires to be applied and the view
expressed by the Kerala High Court cannot be
accepted to be the correct interpretation. We are also
of the firm view that vocational education is a form of
education which is necessary for the development of
an individual for the purpose of earning his living.
Vocational training has been now recognized to be as
important as any other filed of education, and it is for
this reason that National Council for Vocational
Training has been established to streamline and lay
down a systematic pattern of providing education. As
the institute is duly approved by the NCVT, it cannot
be said that the institute is not imparting education."
14. In the case on hand as well, the appellant's activity
includes vocational training for the development of soft skills
of underprivileged, poor and women to develop their skills in
the area of science, arts, business and commerce by providing
various programmes in order to make them employable. The
activity that the appellant is indulged in includes systematic
instructions or training which involves the process of teaching
and learning various subjects. Moreover, in the subsequent
AYs, the appellant has affiliated with Karnataka University,
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Dharwad and is offering Master of Social Entrepreneurship
Course in exchange of fees. Hence, it cannot be stated that
the activities offered by the appellant are not 'education'
under Section 2(15) of the Act.
15. The reasoning given by the AO, CIT(A) as well as
the Tribunal in denying the claim for exemption is that hefty
fees has been charged by the appellant for providing their
services and that there is a major surplus that has been
generated. A perusal at the Books of Accounts would indicate
that in both the AYs, there has been a surplus that has been
generated. However, mere generation of surplus is not a
ground to deny exemption to the appellant. The Hon'ble Apex
Court in CIT v. Surat Art Silk Cloth Manufacturers' Assn.,
reported in (1980) 2 SCC 31 in paragraph 19 has held as
under:
"19. There is, however, one comment which is
necessary to be made whilst we are on this point and
that arises out of certain observations made by this
Court in Sole Trustee, Loka Shikshana Trust case
[(1976) 1 SCC 254 : 1976 SCC (Tax) 14 : (1975) 101
ITR 234] as well as Indian Chamber of Commerce case
[(1976) 1 SCC 324 : 1976 SCC (Tax) 41 : (1975) 101
ITR 796] . It was said by Khanna, J. in Sole Trustee,
Loka Shikshana Trust case [(1976) 1 SCC 254 : 1976
SCC (Tax) 14 : (1975) 101 ITR 234] :
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"[I]f the activity of a trust consists of carrying on a
business and there are no restrictions on its making
profit, the court would be well justified in assuming
in the absence of some indication to the contrary
that the object of the trust involves the carrying on
of an activity for profit."
And to the same effect, observed Krishna Iyer, J. in the
Indian Chamber of Commerce case [(1976) 1 SCC 324
: 1976 SCC (Tax) 41 : (1975) 101 ITR 796] when he
said:
"An undertaking by a business organisation is
ordinarily assumed to be for profit unless expressly
or by necessary implication or by eloquent
surrounding circumstances the making of profit
stands loudly negatived .... A pragmatic condition,
written or unwritten, proved by a prescription of
profits or by long years, of invariable practice or
spelt from some strong surrounding circumstances
indicative of anti-profit motivation -- such a
condition will qualify for charitable purpose."
Now we entirely agree with the learned Judges who
decided these two cases that activity involved in
carrying out the charitable purpose must not be
motivated by a profit objective but it must be
undertaken for the purpose of advancement or carrying
out of the charitable purpose. But we find it difficult to
accept their thesis that whenever an activity is carried
on which yields profit, the inference must necessarily
be drawn, in the absence of some indication to the
contrary, that the activity is for profit and the charitable
purpose involves the carrying on of an activity for
profit. We do not think the Court would be justified in
drawing any such inference merely because the activity
results in profit. It is in our opinion not at all
necessary that there must be a provision in the
constitution of the trust or institution that the
activity shall be carried on no profit no loss basis
or that profit shall be proscribed. Even if there is
no such express provision, the nature of the
charitable purpose, the manner in which the
activity for advancing the charitable purpose is
being carried on and the surrounding
circumstances may clearly indicate that the
activity is not propelled by a dominant profit
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motive. What is necessary to be considered is
whether having regard to all the facts and
circumstances of the case, the dominant object of
the activity is profit making or carrying out a
charitable purpose. If it is the former, the
purpose would not be a charitable purpose, but, if
it is the latter, the charitable character of the
purpose would not be lost."
(emphasis supplied)
16. Moreover, the Hon'ble Apex Court in Queen's
Educational Society v. CIT, reported in (2015) 8 SCC 47
summarised the principles as to 'charitable purpose' qua
'Education'. Albeit, the provision in question in Queen's
Educational Society (supra) was Section 10(23-C) of the Act, it
is relevant to produce paragraph 11 of the judgement which
assumes significance, which is as under:
"11. Thus, the law common to Sections 10(23-
C)(iii-ad) and (vi) may be summed up as follows:
(1) Where an educational institution carries on the
activity of education primarily for educating
persons, the fact that it makes a surplus does not
lead to the conclusion that it ceases to exist solely
for educational purposes and becomes an institution
for the purpose of making profit.
(2) The predominant object test must be applied--
the purpose of education should not be submerged
by a profit-making motive.
(3) A distinction must be drawn between the
making of a surplus and an institution being carried
on "for profit". No inference arises that merely
because imparting education results in making a
profit, it becomes an activity for profit.
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(4) If after meeting expenditure, a surplus
arises incidentally from the activity carried on
by the educational institution, it will not cease
to be one existing solely for educational
purposes.
(5) The ultimate test is whether on an overall
view of the matter in the assessment year
concerned the object is to make profit as
opposed to educating persons."
(emphasis supplied)
17. A reading of the afore-extracted judgements would
make it abundantly clear that, mere generation of
profit/surplus would not be a ground for the Revenue
Authorities to deny the claim for exemption to the assesses.
However, the profits/surplus so generated should be used
solely for educational purposes only. CBDT Circular No. F.
194/16-17-IT(A-I) also clarified the same. It is reproduced
hereunder:
" Circular: No. F. No. 194/16-17-II(A-D).
Availability of exemption - Where
educational institutions/hospitals are
making profits
1. A number of instances have come to the
notice of the Board where action to assess
educational institutions and hospitals have
been taken on the ground that they are
making profit and, therefore, the exemption
under section 10(22) and 10(224) is not
available to them
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2. Under section 10(20) income of an
university or other educational institutions
existing solely for educational purposes and
not for purposes of profit is exempt. Under
section 10(224) income of a hospital or other
institution referred to therein which exists
solely for philanthropic purposes and not for
purposes of profit is also exempt.
3. The question for consideration is whether
an educational institution existing solely for
educational purposes but which shows some
surplus at the end of the year is eligible for
this exemption. If the profit of the educational
institution can be diverted for the personal
use of the proprietor thereof, then the income
of the educational institution will be subject to
tax However, there may be cases where the
educational institutions may be owned by the
trusts or societies to whom the provisions of
section 11 may be applicable. Where all the
objects of these trusts are educational,
and the surplus, if any, from running the
educational institution is used for
educational purposes only, it can be held
that the institution is existing for
educational purposes and not for
purposes of profit. However, if the
surplus can be used for non-educational
purposes, it cannot be said that the
institution is existing solely for
educational purposes and such
institutions will not be liable for
exemption u/s 10(22). But, in such
cases, the applicability of section 11 can
be examined and if the conditions laid
down therein are satisfied, the income
will be exempt under section 11.
4. What has been stated in respect of
educational institutions will equally apply to
hospitals and other institutions referred to in
section 10(224). In the case of hospitals and
similar institutions, if the surplus is used for
philanthropic purposes, the income of the
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institution will be eligible for exemption under
section 10(224). It is not necessary that the
surplus should be used for medical purposes
only."
(emphasis supplied)
18. A perusal of the Audit Reports of the appellant
trust for the relevant AYs would indicate that surplus that has
been generated has been deposited back into the account of
the trust and has not been utilised for non-educational
purposes. Hence, it cannot be stated that the surplus
generated by the appellant trust has been utilised for non-
educational purposes.
19. Thus, for the reasons recorded above and on the
material produced for the relevant Assessment Year, we are of
the considered view that the activity of the appellant is
'education' under Section 2(15) of the Act. Accordingly,
appellant is entitled for exemption under Section 11 of the Act
and thus, Substantial Question of Law No.(i) and (iii) are
answered in favour of the appellant-assessee and against the
revenue. In light of the fact that the Question of Law No.(i)
and (iii) are answered in favour of the assessee, Question of
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Law No.(ii) is rendered academic and is hence, left
unanswered.
20. In the result, the appeal is allowed. The Order of
Tribunal dated 13.10.2016 in ITA Nos.1422 and 1423 (Bang)
2016 is hereby set aside with the aforesaid directions.
Sd/-
(S G PANDIT)
JUDGE
Sd/-
(GEETHA K.B.)
JUDGE
JTR/KMS
