https://www.taxtmi.com/caselaws?id=783684 The dominant issue was whether the assessee-trust qualified as an educational institution "existing solely for educational purposes" under s. 2(15), warranting exemption under s. 11 and continuation of registration under s. 12A. The Tribunal held that "solely" means exclusive, and the assessee's memorandum showed exclusive educational objects in marine engineering education and training, with seminars, research, workshops and technical publications being merely incidental and integrally connected to education. Applying SC law that surplus does not negate charitable character if applied to educational objects, and noting all receipts were utilised for education, the activity was not commercial. The AO's non-compliance with prior Tribunal directions and the CIT(A)'s affirmation were set aside, and exemption under s. 11 was directed to be allowed. en-us Wed, 17 Dec 2025 00:00:00 +0530 Sat, 20 Dec 2025 07:45:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783684 The dominant issue was whether the assessee-trust qualified as an educational institution "existing solely for educational purposes" under s. 2(15), warranting exemption under s. 11 and continuation of registration under s. 12A. The Tribunal held that "solely" means exclusive, and the assessee's memorandum showed exclusive educational objects in marine engineering education and training, with seminars, research, workshops and technical publications being merely incidental and integrally connected to education. Applying SC law that surplus does not negate charitable character if applied to educational objects, and noting all receipts were utilised for education, the activity was not commercial. The AO's non-compliance with prior Tribunal directions and the CIT(A)'s affirmation were set aside, and exemption under s. 11 was directed to be allowed. Case-Laws Income Tax Wed, 17 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783684