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Whether the assessee-trust's vocational training and skill development programmes for underprivileged persons, conducted for fees and generating surplus, constituted "education" under s. 2(15) so as to qualify for exemption u/s 11, was answered in the affirmative. Applying the test that "education" involves a formal and systematic process of instruction or training, the trust's structured vocational courses, including later affiliation with a university for a post-graduate programme, were held to fall within "education" rather than "advancement of general public utility"; hence the proviso to s. 2(15) was not attracted. Mere surplus generation was held insufficient to deny exemption where audit material showed the surplus was ploughed back for educational objects and not diverted. Exemption was allowed and the denial by the authorities was set aside - HC
Whether the assessee-trust's vocational training and skill development programmes for underprivileged persons, conducted for fees and generating surplus, constituted "education" under s. 2(15) so as to qualify for exemption u/s 11, was answered in the affirmative. Applying the test that "education" involves a formal and systematic process of instruction or training, the trust's structured vocational courses, including later affiliation with a university for a post-graduate programme, were held to fall within "education" rather than "advancement of general public utility"; hence the proviso to s. 2(15) was not attracted. Mere surplus generation was held insufficient to deny exemption where audit material showed the surplus was ploughed back for educational objects and not diverted. Exemption was allowed and the denial by the authorities was set aside - HC
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