Dismissing the appeal of the Revenue  The Tribunal held  that the corporate receipts were mainly flowing from the Corporate Social Responsibility obligations of the concerned business houses which could not be viewed or characterised as aimed at profiteering. Those corporate donations were asserted to have been utilised solely for the purposes of the educational activities which were undertaken by the assessee and the veracity of these facts was not contested by the Revenue. Section 2(15) as being concerned with training and developing knowledge, skill, mind and character by formal schooling. The tests as propounded by the Supreme Court were met by the assessee.  The mode and manner in which education was imparted would be a concept which would have to necessarily be evaluated considering the march of technology and the myriad modes of imparting instruction which presently exists and have enabled institutions to overcome barriers of distance and time. Imparting of education through a virtual mode or by the adoption of new technologies would not detract from such activity, otherwise fulfilling the requirements of structured education. The test, as propounded by the Supreme Court required to evaluate whether a formal and systematic process of imparting education had been adhered to. Approving and affirming the observations of the Tribunal to the effect that the whole world is experiencing “new normal” in all spheres of activities and education is no exception, that classrooms have no bricks and mortar, no benches and blackboards, that “blackboard collaborate” and digital white boards have replaced blackboards, that the teachers and students do not assemble at one place but they reach each other on cloud through Meets, Teams, WebEx and Zoom! and such cloud classes have wide representation of students across the globe blurring the geographies of traditional classrooms, that students love polls, live question and answer sessions and prerecorded videos, that books and notebooks have been replaced by smart phones and tabs, that attendances are also virtual instead of physical, that chat boxes are medium of group discussion, that timings are 24/7, that still it has all the essentials of a “classroom” and covers “process of training, developing the knowledge, skill, mind and character of students like normal schooling and that therefore, in true sense the activities performed by the assessee were no different from “classrooms”, that the educational activities carried on were covered by the provisions of section 2(15) and were neither business nor profession of the assessee but constituted charitable activities since it did not charge the fees at the level of market rate and even otherwise the surplus generated was also used for charitable activities of education as found by the Assessing Officer for the assessment year 2014-15 and for earlier assessment years and therefore, his order under section 143(3) was not erroneous, and that therefore the order passed by the Commissioner (E) under section 263 for the assessment year 2014-15 was quashed and set aside. Considering the conclusions on the principal issue of section 2(15), the question with respect to whether the Commissioner (E) was justified in invoking its powers conferred by section 263 was insignificant hence not  answered. Ratio in New Noble Education Society v. CIT (2022) 448 ITR 594 (SC) ; 2023) 6 SCC 649, relied on. Explained the ratio in  Ratio,Sole Trustee, Loka Shikshna Trust v.CIT (1975) 101 ITR 234 (SC) ; (1976) 1 SCC 254   (AY. 2014-15)