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The ITAT held that training and development activities conducted by the educational entity constitute a legitimate educational pursuit under section 2(15), not a commercial activity. The structured training programs, involving attendance records, examinations, and certifications, are integral to the organization's educational objectives. The tribunal rejected revenue's contentions that these activities were separate business operations, emphasizing that such skill development programs are part of continuing education. Consequently, the assessee was deemed eligible for exemption under section 11(1)(a), with the training activities considered an extension of academic pursuits rather than a distinct commercial endeavor.
The ITAT held that training and development activities conducted by the educational entity constitute a legitimate educational pursuit under section 2(15), not a commercial activity. The structured training programs, involving attendance records, examinations, and certifications, are integral to the organization's educational objectives. The tribunal rejected revenue's contentions that these activities were separate business operations, emphasizing that such skill development programs are part of continuing education. Consequently, the assessee was deemed eligible for exemption under section 11(1)(a), with the training activities considered an extension of academic pursuits rather than a distinct commercial endeavor.
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