Educational institution test under section 2(15): regulatory professional body treated as general public utility, not education.

An institute whose dominant statutory role is to regulate a profession, conduct examinations, prescribe qualifications, maintain standards, and enforce discipline does not qualify as an educational institution merely because it also provides coaching, training, or post-qualification courses. The term "education" in section 2(15) was read in the limited sense of systematic instruction or formal schooling, and the institute's activities were held to be only ancillary to its regulatory functions. It therefore fell within the residuary charitable category of advancement of any other object of general public utility, rather than the educational limb of section 2(15).

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Issues: (i) Whether the petitioner institute was an educational institution or fell within the residuary limb of charitable purpose as advancement of any other object of general public utility under section 2(15) of the Income-tax Act, 1961.

Analysis: The institute's main and dominant function under the Chartered Accountants Act, 1949 was to regulate the profession of chartered accountants, conduct examinations, prescribe qualifications, maintain standards, and exercise disciplinary control. Its coaching, training, and post-qualification courses were held to be only ancillary to its statutory and regulatory objects. The term "education" in section 2(15) was construed in the limited sense of systematic instruction or formal schooling, and the institute's activities did not answer that description. The institution therefore fell under the sixth limb of section 2(15), namely advancement of any other object of general public utility.

Conclusion: The institute was not held to be an educational institution; it was held to fall within the residuary charitable category of advancement of any other object of general public utility.

Ratio Decidendi: An institution whose dominant statutory function is regulation of a profession, and whose teaching or coaching activities are merely incidental, does not become an educational institution for section 2(15) purposes.

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