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. The activity of providing vocational training to rural youth to develop their skills in the areas of science, technology, arts, etc., by providing various programmes in order to make them employable in exchange for fees is covered by the term ‘education used in section 2(15). Similarly, mere generation of profit/surplus would not be a ground for the revenue authorities to deny the claim for exemption under section 11 to the assessee when such surplus is utilised for educational purposes or not utilised for non-educational purposes. (AY.2011-12, 2012-13)
Deshpande Education Trust v. ACIT (2026) 349 CTR 93 / 309 Taxman 106 (Karn)(HC)
S. 11: Property held for charitable purposes-Providing systematic instructions or training which involves a process of teaching and learning amounts to “providing education” for purposes of section 2(15)-Mere generation of surplus would not be a ground to deny exemption to assessee under section 11 when the surplus so generated was used solely for educational purposes-Entitled to exemption. [S. 2(15), 12AA]
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