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2012 (12) TMI 1052

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.... According to the ld. representative, the taxpayer institution is functioning in Cherthala which is educationally and socially backward area. The taxpayer has given substantial reduction in fees to financially backward and weaker students. The entire income derived by way of fees was spent for charitable purpose. Therefore, the Administrative Commissioner is not correct in rejecting the application of the taxpayer for registration. 3. On the contrary, Smt. S Vijayaprabha, the ld. DR submitted that the taxpayer is conducting only coaching classes. The taxpayer is not running any institution for systematic schooling. Therefore, according to the ld. DR, coaching classes conducted by the taxpayer will not come within the meaning of "education"....

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....es education. According to this wide and extended sense, travelling is education, because as a travelling you acquire fresh knowledge. Likewise, if you read newspapers and magazines, see pictures, visit art galleries, museums and zoos, you thereby add to your knowledge. Again, when you grow up and have dealings with other people, some of whom are not straight, you learn by experience and thus add to your knowledge of the ways of the world. If you are not careful, your wallet is liable to be stolen or you are liable to be cheated by some unscrupulous person. The thief who removes your wallet and the swindler who cheats you teach you a lesson and in the process make you wiser though poorer. If you visit a night club, you get acquainted with a....

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....1965) 55 ITR 722 (SC) and in the case of CIT v. Sole Trustee, Loka Shikshana Trust (1970) 77 ITR 61 (Mys) has observed as follows at page 615 of the ITR: "It is true that by reason of the Finance Act, 1983, the question as to whether any charitable institution is being run with a profit motive or not has lost its relevant. However, the word "charitable" prefixing the word "institution" has to be given its full effect. It appears that one of the principal projects of the petitioner's institution has the object of coaching and preparing the students for appearing in various examinations conducted by the Board of Mining Examination and/or MI(1) section (a)(b) and the said coaching of students in an institute is not, in our opinion, an im....