Charitable registration for educational trusts requires formal, systematic scholastic instruction; open-schooling activities were held insufficient.

Registration under section 12AB was refused because the trust's Gurukulam and open-schooling activities were not found to constitute education in the statutory charitable sense. The Tribunal applied the Supreme Court's standard that educational activity must involve formal, systematic scholastic instruction, and held that the trust had not established relief of the poor or any infirmity in the rejection of registration. The denial of registration was therefore upheld and the appeals failed.

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Issues: Whether the assessee-trust was entitled to registration under section 12AB on the footing that its activities fell within the charitable objects of education and relief of the poor.

Analysis: The Trust claimed that it was running educational activities through a Gurukulam/open-schooling model and that its curriculum, recognition efforts, and expenditure showed charitable activity. The Revenue and the order under challenge proceeded on the basis that the activities did not amount to education in the statutory sense and that the Trust had not established relief of the poor. The Tribunal accepted the view that the activities failed to satisfy the requirements laid down by the Supreme Court for education as a charitable purpose, namely formal schooling or systematic scholastic instruction, and found no infirmity in the rejection of registration.

Conclusion: The Trust was not entitled to registration under section 12AB; the rejection was upheld.

Final Conclusion: The appeals failed and the denial of registration remained undisturbed.

Ratio Decidendi: For registration under section 12AB, activities claimed as education must constitute formal, systematic scholastic instruction and must satisfy the statutory charitable-purpose test; a trust that does not meet that standard can be refused registration.

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